New Bank Bill Forces Regulators to Approve Mergers in 90 Days or They Pass Automatically

The aptly named Bank Failure Prevention Act of 2025 doesn’t actually focus on preventing failures, but on radically speeding up how bank holding companies, savings and loan holding companies, and insured depository institutions get approval for mergers and acquisitions. Essentially, this bill puts a hard 90-day clock on financial regulators, forcing them to approve or deny complex applications—or watch them pass automatically.

The 90-Day Sprint: Automatic Approvals Are the New Default

Right now, when a large bank holding company wants to merge or make a significant structural change, the Federal Reserve (the Board) or the FDIC has to review the application. That review process can take time, especially for multi-billion dollar deals that require deep dives into financial stability and risk. This bill (Section 2) changes that: the agency only gets 90 days from the initial submission date to make a decision. If they don’t meet that deadline, the application is automatically approved. The only way to extend that 90-day window is if the applicant specifically asks for up to 30 extra days. Think of it like this: the financial regulators, who are supposed to be the referees, are now under a severe time constraint, and if the clock runs out, the team on the field scores a point by default.

The 'Completeness' Loophole: Regulators Can't Fact-Check

This bill also restricts how regulators can determine if the initial application paperwork is complete. Under the new rules (Section 2), when the regulator checks the application, they can only look at information provided by the applicant. They can’t use external data, their own institutional knowledge, or publicly available information to say, “Wait, this application is missing crucial context.” They have 30 days to tell the applicant what’s missing, but that completeness check is now artificially blind. This means a bank could potentially submit a technically complete but strategically misleading application, forcing the regulator to start the 90-day review clock without the full picture.

What This Means for Financial Stability

If you’re a busy person trying to manage your own finances, why should you care about bank merger timelines? Because the regulators’ job is to vet these deals to ensure they don't create new systemic risks—the kind of risks that can lead to taxpayer bailouts or economic instability down the road. By imposing a hard 90-day deadline enforced by automatic approval, the bill forces regulators to prioritize speed over thoroughness, particularly on highly complex mergers. For example, if a major regional bank applies to acquire a competitor, the regulator might spend the entire 90 days just trying to understand the combined entity’s exposure to complex assets. If they hit day 91 without a formal decision, that merger—regardless of how risky it might be—is rubber-stamped. This dramatically increases the chance that insufficiently vetted, high-risk financial transactions could be approved simply because the government couldn't move fast enough, putting the burden of risk back on the broader financial system and, ultimately, the public.