Comment Letter: Greenlining Comments to OCC and FDIC on Bank Merger Regulation

Comments to the Federal Deposit Insurance Corporation on Proposed Statement of Policy on Bank Merger Transactions
The Federal Deposit Insurance Corporation (FDIC) requested comments on their Proposed Statement of Policy on Bank Merger Transactions in June 2024. The FDIC’s proposed rule intended to increase clarity and transparency to the public regarding their review of bank merger applications. In this timely update to their statement of policy, the FDIC made progress by setting clear expectations that applicants demonstrate how the bank plans to improve post merger conditions through products and services. Greenlining recommended that additional guidance on the use of Community Benefit Agreements (CBA) are essential for accountability to meet the convenience and needs of the community, and continued to advocate for CBA’s to be a legally binding agreement between community members and bank’s CEOs.
You can read the full comment letter here.
Comments to the Office of the Comptroller of the Currency on Business Combinations under the Bank Merger Act
The Office of the Comptroller of the Currency (OCC) requested comments on their Notice for Proposed Rulemaking for Business Combinations under the Bank Merger Act in April 2024. The proposed rule aimed to increase clarity and transparency to the public regarding the factors that the OCC considers when reviewing bank merger applications. Greenlining provided comments on the disproportionate impacts that bank mergers continue to have in low income and communities of color, causing ripple effects in local economies due to job losses, branch closures, and reduction in affordable products and services. Greenlining upheld the importance of Community Benefit Agreements (CBAs) in mitigating these local impacts and continued to advocate for CBA’s to be a legally binding agreement between community members and bank’s CEOs.
You can read the full comment letter here.
