In its order approving People’s United Financial, Inc.’s acquisition of Suffolk Bancorp, the Board of Governors of the Federal Reserve System (“FRB”) revised the presumption it will apply when analyzing whether a proposed bank acquisition transaction would result in greater or more concentrated risks to the stability of the United States banking or financial system. A 2012 order approving the acquisition of ING Bank, fsb by Capital One Financial Corporation first established the FRB’s presumption that a transaction that involves an acquisition of less than $2 billion in assets or results in a firm with less than $25 billion in total assets would not raise material financial stability concerns. In the People’s United order, the FRB revised this presumption to apply to a transaction that involves an acquisition of less than $10 billion in assets or results in a firm with less than $100 billion in total assets, absent evidence that the transaction would result in a significant increase in interconnectedness, complexity, cross-border activities or other risk factors.