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Davis Polk says it published takeaways from the FDIC’s proposed bank merger rule
Davis Polk said it published an analysis of the FDIC’s 2026 proposed bank merger rule. The firm’s article examined the proposed application and review framework and compared how different transaction characteristics could affect processing, competition analysis and the assessment of financial stability and community factors.
Key points
- Davis Polk described three processing tracks for merger applications.Davis Polk
- The firm examined the proposed treatment of applications deemed substantially complete.Davis Polk
- Davis Polk discussed an 80% threshold over 12 months for mergers in substance and a 25% significant asset transfer threshold.Davis Polk
- The firm included an appendix comparing procedural requirements and discussed competition safe harbors.Davis Polk