AL101722

2022-10-14T17:07:31-04:00October 14th, 2022|3- This Week|

Ouch?

Later this week, the FDIC board will decide whether to hike DIF premiums as proposed earlier this year (see FSM Report DEPOSITINSURANCE114).  The banking industry is arrayed against this not only because it’s costly, but also – as our analysis addressed – procyclical.  We will provide clients with an in-depth analysis of the final rule along with the meeting, which now also includes a certain vote in favor of FDIC agreement to the ANPR released late last week by the Fed asking an array of questions on large-bank resolvability.  We will also provide clients with an in-depth analysis of this ANPR along with the accompanying orders setting new merger policy by way of the Fed and OCC decisions on the USB/MSFG transaction.  These actions make it clear that mergers will be approved even in the absence of the formal Fed policy promised by Vice Chairman Barr, but the terms and conditions will be considerably stricter than was the case just a year ago for other super-regional transactions.

Al101722.pdf