This Act mandates regular Inspector General reviews of how federal banking agencies process insured depository institution merger applications to improve efficiency and timeliness.
Roger Williams
Representative
TX-25
The Merger Process Review Act mandates that the Inspector General of each federal banking agency regularly review how merger applications from banks and credit unions are processed. These reviews will evaluate processing times, identify sources of delay, and offer recommendations for improving efficiency. Following each review, the agency must submit a formal response and implementation plan to Congress.
The “Merger Process Review Act” isn’t about changing who can merge—it’s about checking the internal clock of the government agencies that approve those mergers. Think of it as a mandatory efficiency audit for the financial regulators.
This bill targets the federal agencies overseeing banks and credit unions, like the Federal Reserve, the FDIC, and the National Credit Union Administration (NCUA). It mandates that the Inspector General (IG) of each agency must conduct a regular review of how long it takes them to process applications for bank and credit union mergers. The first review is due within a year, with follow-ups every three years after that (SEC. 2).
For most people, the speed of a bank merger application feels like a background hum, but it matters for the financial system and, indirectly, for consumers. If a merger drags on for months or years, it can delay decisions about branch closures, service changes, and even lending policies. This bill requires the IGs to measure the mean and median processing times and identify exactly what is causing delays in the system (SEC. 2).
In plain terms, the IG is asking the regulators: Are you getting these done efficiently, or are you letting paperwork pile up on a desk somewhere? The goal is to find bottlenecks and suggest specific ways to speed things up, provided those changes still allow the agencies to do their required legal due diligence.
If the process becomes more efficient, the primary beneficiaries are the banks and credit unions themselves, who can execute their business plans faster. For customers, a quicker merger means less time in limbo regarding their accounts, loan terms, or access to services. If a small, local credit union is merging with a larger regional bank, this bill aims to make sure the transition doesn’t take forever, which is good news for the account holders who need clarity.
After each review, the IG has to send a report to Congress detailing all the findings. Then, the regulated agency has to send its own response, including a plan for implementing the IG’s recommendations—but only “to the extent the agency finds implementation appropriate.” This is the key caveat (SEC. 2).
This language means the agencies still have the final say. They can’t just ignore the report, but they can effectively look at a suggestion to eliminate a specific review step and say, “Thanks, but we think that step is actually crucial for protecting consumers, so we’re keeping it.” While the bill promotes transparency and efficiency, it doesn’t force the regulators to adopt any change they believe compromises their legal duties or oversight responsibilities. It’s a push for better performance, but the agencies still hold the steering wheel.