September 15, 2025
On September 8, 2025, the OCC announced actions, including issuing two Bulletins, to “end the weaponization of the financial system” by “rooting out” activities that “unlawfully debank or discriminate against customers on the basis of political or religious beliefs, or lawful business activities.” Our Legal Update, available here, describes the OCC’s plan to start reviewing banks’ debanking practices in licensing application reviews and CRA evaluations, and the agency’s instructions to banks regarding responding to government information requests and preparing SAR filings. Our Legal Update also offers a number of tips for OCC-supervised institutions prepare for further scrutiny from the agency regarding this issue.
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March 3, 2025
To our clients and friends:
Today we published Volume 15 of The Bankers’ Bulletin, providing our insights into key banking industry developments from February 2025, including:
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July 30, 2024
To our clients and friends:
The Federal Trade Commission’s ban on most non-competition agreements continues to make its way through various courts. Attached is an Alert which covers the two most recent court decisions, and the Alert is available here.
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May 2, 2024
To our clients and friends:
On April 23, 2024, the Federal Trade Commission issued a final rule that bans most non-competition agreements.
Our Alert, which covers what financial institutions need to know about the final rule, is available here.
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April 3, 2024
To our clients and friends:
On March 21, the FDIC proposed revisions to its Statement of Policy on Bank Merger Transactions, which are intended to provide guidance on how the agency reviews merger applications under the Bank Merger Act. Our Client Alert describes the most relevant aspects of the new policy statement and includes key takeaways that will be important for banks considering future merger and acquisition activity. Our Alert regarding the FDIC’s proposed changes to its policy statement process is available here.
Luse Gorman has acted as counsel on more than 100 bank M&A transactions during the past five years and more bank M&A transactions than any other law firm in the nation over the past 20 years. Luse Gorman regularly works with federal and state banking agencies to seek regulatory approval for business transactions, including mergers and acquisitions, and routinely handles complex and novel legal questions on behalf of its clients as they arise. To learn more about our firm and services, please visit our website.
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