FDIC’s Final Statement of Policy on Bank Merger Transactions

Summary

On September 17, 2024, the FDIC Board of Directors approved a final Statement of Policy on Bank Merger Transactions (Final SOP).  The Final SOP communicates the Board’s expectations for merger transactions subject to FDIC approval, including the analytical considerations that go into evaluating each statutory factor in a forward-looking manner.  The Final SOP supersedes the prior Statement of Policy on Bank Merger Transactions 30 days after publication in the Federal Register.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-insured financial institutions.

Highlights:

The Final SOP:

• Replaces the existing Statement of Policy, which was last revised in 2008. 
• Updates, strengthens, and clarifies the FDIC’s policies and expectations related to the evaluation 

of bank merger transactions.

• Refines, and in some cases, broadens the description of the analytical considerations for each statutory factor. 
• Includes changes made in consideration of the 23 comment letters submitted in response to the FDIC’s April 2024 Request for Comment on a proposed Statement of Policy Regarding Bank Merger Transactions.