What changed between these versions
A substantive expansion of the bill's scope and a refinement of application processing timelines. v2 adds a new section extending the application completeness and determination rules to insured depository institutions, and modifies existing provisions for bank and savings and loan holding companies to allow for applicant-requested deadline extensions and to broaden the criteria for extending initial notice periods.
Overview
A handful of significant changes across multiple sections. · v2 expands the applicability of the bill's provisions to a new category of financial institutions and refines the procedural timelines for all covered entities, generally providing more flexibility for applicants to request extensions.
The most significant change in v2 is the addition of an entirely new subsection, Section 2(c), which extends the application completeness and determination rules to merger applications for insured depository institutions under the Federal Deposit Insurance Act. Additionally, v2 introduces a new provision allowing the Board to extend the final 90-day application determination deadline by up to 30 days at the applicant's request for both bank and savings and loan holding companies. Minor modifications were also made to the criteria for extending the initial notice period and the phrasing regarding third-party information.
Major additions
This new clause allows the Board to extend the 90-day deadline for granting or denying an application for bank holding companies by up to 30 days, specifically at the request of the applicant.
This provides applicants with a mechanism to request additional time for the Board's review beyond the statutory 90-day period, potentially offering more flexibility in complex cases or when additional time is needed for discussions.
Similar to the addition for bank holding companies, this new clause permits the Board to extend the 90-day deadline for savings and loan holding company applications by up to 30 days, upon the applicant's request.
This grants savings and loan holding company applicants the same procedural flexibility to request extensions for application determinations, aligning with the changes made for bank holding companies.
This entirely new subsection extends the application completeness and determination rules to merger applications for insured depository institutions under Section 18(c) of the Federal Deposit Insurance Act. It establishes a 30-day notice period for completeness, allows for a 30-day extension for 'unusually complex' applications, outlines the process for deeming a record complete, excludes third-party information from completeness determinations, sets a 90-day deadline for determination, and includes a new provision for applicant-requested extensions of up to 30 days.
This significantly broadens the scope of the bill by applying the same streamlined application processing and deadline requirements, including the new extension provisions, to a new category of financial institution mergers. This could impact a large number of merger transactions involving insured depository institutions.
Modifications
This change makes it slightly easier for the Board to extend the initial 30-day period for notifying an applicant about the completeness of their submission, potentially leading to more frequent use of this extension for a wider range of applications.
Before
The Board could extend the 30-day period for confirming application completeness if an application was 'unusually complex'.
After
The Board can now extend the 30-day period for confirming application completeness if an application is simply 'complex'.
This change refines the language to more precisely state that the *completeness determination* itself cannot be based on third-party information, without altering the underlying policy.
Before
Stated that the Board 'may not base the determination of the Board on any information' from third parties when determining if a record is complete.
After
Clarified that the Board 'may not base the determination of completeness on any information' from third parties.
Similar to bank holding companies, this makes it slightly easier for the Board to extend the initial 30-day period for notifying a savings and loan holding company applicant about the completeness of their submission.
Before
The Board could extend the 30-day period for confirming application completeness if an application was 'unusually complex'.
After
The Board can now extend the 30-day period for confirming application completeness if an application is simply 'complex'.
This change refines the language to more precisely state that the *completeness determination* itself cannot be based on third-party information, without altering the underlying policy.
Before
Stated that the Board 'may not base the determination of the Board on any information' from third parties when determining if a record is complete.
After
Clarified that the Board 'may not base the determination of completeness on any information' from third parties.
Scope
Meaningful expansion or narrowing — Changes are scattered across the bill, affecting both bank holding companies and savings and loan holding companies, and introducing a new, comprehensive section for insured depository institutions. — v2 represents a meaningful expansion of the bill's policy direction by applying its framework to a new category of financial institutions (insured depository institutions). It also refines existing procedural aspects for other entities. — The new Section 2(c) directly interacts with and amends Section 18(c) of the Federal Deposit Insurance Act, imposing new procedural requirements and deadlines on merger applications under that existing law.
Impact analysis
Bank Holding Company applicants
Procedural benefit/gain
Gain the ability to request an extension of up to 30 days for the final application determination deadline. The criteria for the Board to extend the initial completeness notice period are also slightly broadened.
Savings and Loan Holding Company applicants
Procedural benefit/gain
Gain the ability to request an extension of up to 30 days for the final application determination deadline. The criteria for the Board to extend the initial completeness notice period are also slightly broadened.
Insured Depository Institutions applying for mergers
Procedural change/benefit
Are now subject to the bill's specific rules regarding application completeness notices, deadlines for determination, exclusion of third-party information from completeness reviews, and the ability to request a 30-day extension for the final determination.
The Board of Governors of the Federal Reserve System (for BHC and SLHC applications) and responsible agencies (for IDI merger applications)
Procedural change
The Board/agencies now have the explicit authority to grant applicant-requested extensions for final determinations (up to 30 days). The criteria for extending the initial completeness notice period are slightly broadened for BHCs and SLHCs (from 'unusually complex' to 'complex'), while remaining 'unusually complex' for IDIs.