FDIC merger clock drops to 64 days

The FDIC board voted unanimously on Sept. 17 to approve a proposed rule that codifies specific timelines for bank merger reviews. The aim is to make the process faster and more predictable. Chairman Travis Hill said the change responds to a banking landscape that has diverged significantly from the era when the Bank Merger Act was written, arguing that a modernized analytical framework is now required.

Hill noted that the average time from application receipt to final action has fallen from 107 days in 2023 and 2024 to 80 days in 2025, and to 64 days so far in 2026. The proposal would formalize this progress by establishing a "rapid processing" framework for de minimis transactions. These acquisitions, defined as targets that are extremely small or specific types of operating subsidiaries, would be processed in as little as five days.

"The proposal would take the additional step of codifying a series of timelines for processing different types of merger applications," Hill said. "This would include a 'rapid processing' framework for de minimis transactions, which are acquisitions of extremely small targets or certain types of operating subsidiaries and which would be processed in as little as five days."

The rule also expands the competitive effects analysis to include credit unions and centrally booked deposits. It creates a mechanism where de minimis cases receive automatic sign-off via correspondence and limits the agency's discretion to remove filings from expedited processing. Once the Federal Register publishes the proposal, the public has 60 days to submit feedback to the FDIC.