Although all of the banking agencies have for years promised a new bank-merger policy, none has proposed one until this OCC rulemaking. It is intended to add certainty and transparency to the manner in which the OCC reviews merger applications or others for charter combinations from national banks and federal savings associations resulting in a federally-chartered depository, but the OCC retains discretion to do as it chooses in this arena given the flexibility built into all the attributes now laid out that may augur OCC disapproval and/or expedited processing. The policy also appears to apply to…
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