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OCC’s Hsu: Herfindahl-Hirschman Index review on the table


Prepared remarks from Acting Comptroller of the Currency Michael Hsu reiterated his push for regulators to review federal frameworks for bank mergers.

February 13, 2023 / By ICBA

Prepared remarks from Acting Comptroller of the Currency Michael Hsu reiterated his push for regulators to review federal frameworks for bank mergers.

Regulatory Review: Hsu’s remarks—delivered by OCC Chief Counsel Ben McDonough at an agency forum on behalf of Hsu—call for an update of merger standards, including revising Herfindahl-Hirschman Index market concentration calculations to better account for nonbank competitors, which is an ICBA priority.

Background: Hsu last year directed senior OCC staff to work with the Justice Department and other agencies to review federal merger standards.

ICBA Position: In a comment letter to the FDIC last year, ICBA laid out its plan for revising merger policies, including faster reviews of community bank mergers, consulting the Justice Department on mergers of the largest institutions, and incorporating credit unions into the Herfindahl-Hirschman Index.

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