Banking Applications: Federal Reserve Provides New Insight Regarding Consideration of Banking Applications and Notices; Announces New Semi-Annual Publication of Banking Application Data

Sullivan & Cromwell LLP - May 1, 2014

Supervisory Letter No. SR 14-2/CA 14-1 (the “Letter”), issued by the Board of Governors of the Federal Reserve System (the “Federal Reserve”), discusses various issues that may prevent the Federal Reserve from acting favorably on applications and notices submitted by banking organizations.  In particular, the Letter (a) describes the Federal Reserve’s approach to processing applications and notices that present such issues and (b) provides relevant statistics for the period 2009 to 2012.  The Federal Reserve also announced the forthcoming publication of a new semi-annual report (the “Semi-Annual Report”) that will include aggregate statistics regarding the consideration and disposition of applications and notices, including the length of time taken to process them, the number of approvals, denials, and withdrawals, and the primary reasons for withdrawals.  Currently, the Federal Reserve releases a weekly report that details, among other things, its actions on banking applications and notices, but this publication does not include aggregate data, explanations for its actions, or other information regarding these applications and notices.  The first Semi-Annual Report will cover the first half of 2014 and be published in the second half of 2014.