Federal Reserve and OCC Consideration of Bank Merger Proposals

Federal Reserve’s and OCC’s Recent Approval Orders for Larger Bank Mergers Demonstrate Adherence to the Existing Statutory Review Framework Sullivan & Cromwell LLP - January 18, 2023

The Federal Reserve Board and Office of the Comptroller of the Currency (“OCC”) on Tuesday approved Bank of Montreal’s applications to acquire Bank of the West from BNP Paribas S.A. As with the Federal Reserve’s and OCC’s October 2022 approval orders authorizing U.S. Bancorp’s acquisition of MUFG Union Bank, N.A., these orders demonstrate the willingness of the Federal Reserve and OCC to approve proposed merger transactions, even for larger organizations, that satisfy the existing statutory requirements set forth in the Bank Holding Company Act of 1956 and the Bank Merger Act, respectively.

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