Davis Polk partner David Portilla was quoted in IFLR discussing updated bank merger guidelines.

In September, the OCC, the FDIC and the DOJ made policy announcements on how they intend to look at bank mergers. David noted that the analysis of bank mergers will change because the regulators set out a lot of detail to describe how they would be changing it.

“We don’t know how it will change until meaningful transactions are put before the agencies. There will be uncertainty until we see the policy adjustments,” he said.

“Large transactions are still viable,” he continued, “but they require a new style of analysis than would have been the case prior to the DOJ and the agencies announcing their new approach.”

Discussing how the election in November could impact the approach to bank mergers, David said, “Any election will have an impact, but it’s really hard to tell how. The old maxim that the personnel is the policy is a good one. Until you know who the personnel are, it’s hard to know how things will be affected.”

“US bank mergers still challenging for clients, say lawyers,” IFLR (October 14, 2024) (subscription required)

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