Merger Process Review Act
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Would require the Inspector General of each federal banking regulator — the Federal Reserve, the Office of the Comptroller of the Currency, the FDIC, and the National Credit Union Administration — to review their agency's bank merger application process every three years and report findings to Congress.
The bill targets concerns about delay and inconsistency in how regulators handle merger applications from banks and credit unions, requiring each agency to respond to its OIG's findings with a written implementation plan.
What this bill would do
What it would do
The bill would require the Inspector General of each of the four federal banking regulators to conduct a formal review of that agency's procedures for handling insured depository institution merger applications — covering banks, thrifts, and credit unions. The first review would be due within one year of enactment, with additional reviews every three years. Each review would evaluate quantifiable metrics such as mean and median processing times, identify sources of delay, assess the benefits and risks of different review approaches, and examine the impact of approved mergers on safety, competition, and financial product availability. OIGs would report findings and specific recommendations to Congress and publish reports online.
The bill would not itself change the substantive legal standards for approving or denying mergers. After each OIG report, the relevant agency would be required to submit a written response — including a plan to implement the OIG's recommendations to the extent the agency considers appropriate — but the agency retains discretion over which recommendations to adopt.
Key provisions
- 1Would require the Inspector General of each federal banking regulator to review the agency's merger application review procedures within one year of enactment and every three years thereafter.
- 2Would mandate each review include quantifiable metrics such as mean and median application processing times and identification of sources of delay.
- 3Would require each review to assess the impact of merger review procedures and approved mergers on safety and soundness, financial stability, competition, and availability of financial products.
- 4Would require each OIG to report its findings and recommendations to Congress and publish the report online at the conclusion of each review.
- 5Would require the relevant federal regulator to submit to Congress and publish online a written response and implementation plan in response to each OIG report.
Who would be affected
The four federal banking regulators and their Inspectors General bear the primary new obligations. Banks, thrifts, bank holding companies, and credit unions that apply for merger approval under the identified statutes stand to benefit indirectly if reviews surface and correct processing delays. Congress receives the reports and gains a regular oversight mechanism over federal merger review practices.
Why it matters
Applicants seeking merger approvals have long cited unpredictable timelines as a cost and planning burden. If OIG reviews surface systemic delays or procedural inconsistencies and agencies act on the recommendations, institutions could face a more efficient and predictable approval process. The reporting requirement also gives Congress a structured basis for oversight that does not currently exist in a standardized form.
What would change
Changes to existing law
Amends Federal Deposit Insurance Act (Sec. 2(d))
Referenced as the source of definitions for insured depository institutions and merger application types covered by the bill's review requirement.
Amends Federal Credit Union Act (Sec. 2(d))
Referenced to define insured credit unions and the credit union merger application type subject to OIG review.
Amends Bank Holding Company Act of 1956 (Sec. 2(d))
Sections 3 and 4 applications for bank holding company acquisitions are included in the scope of merger applications subject to OIG review.
Amends Home Owners' Loan Act (Sec. 2(d))
Section 10(e) applications for thrift acquisitions are included in the scope of merger applications subject to OIG review.
Agencies directed to act
Effective dates
- First OIG review of merger application procedures due
How implementation would work
Within one year of enactment, each of the four OIGs would complete and publish a review. Every three years thereafter, the cycle repeats. Each review must include quantitative processing-time metrics, a qualitative assessment of delay sources, and specific improvement recommendations. The OIG publishes the report to Congress and online; the regulator then publishes a written response with an implementation plan. No rulemaking is required; the bill is self-executing through existing OIG authority, and no additional funding is authorized.
Legislative status & sources
Latest action
Placed on the Union Calendar, Calendar No. 453.
Official CRS summary
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This bill requires the appropriate Office of the Inspector General (OIG) that serves the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration to periodically review the merger applications received by that regulator.
Specifically, every three years, the appropriate OIG must examine that regulator’s merger approval procedures, including timeliness and efficiency, and report on its findings and recommendations. The regulator must then submit a plan to implement the appropriate recommendations.
Legislative subjects
Banking and financial institutions regulation; Business records; Congressional oversight; Corporate finance and management; Finance and Financial Sector; Government information and archives; Government studies and investigations; Licensing and registrations; Performance measurement
Committee report
H. Rept. 119-528