Legal Update – FDIC Proposes to Modernize Processing and Evaluation of Bank Mergers, and Promote Parity for State Banks and National Banks Providing Services Out-of-State

September 25, 2026

To our clients and friends:

On September 17, 2026, the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking on merger transactions to fundamentally reform the FDIC’s framework for processing and evaluating merger transactions under the Bank Merger Act and a second proposed rule on State bank parity to establish parity between out-of-state State banks and national banks regarding the application of host State laws. Our Legal Update on this proposal can be found here.

Luse Gorman, PC regularly advises financial institutions on regulatory and compliance developments of, supervisory relationships with, enforcement actions from, and licensing applications to, the federal banking and credit union regulatory agencies. If you have any questions related to this Legal Update, please reach out to your Luse Gorman contact. To learn more about our firm and services, please visit our website.

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Scott A. Brown and Jeffrey M. Cardone presented on M&A Insights From an Attorney’s Perspective at the AICPA Conference on Banks & Savings Institutions and Conference on Credit Unions

September 18, 2026

On September 15, 2026, Scott A. Brown and Jeffrey M. Cardone presented at the AICPA Conference on Banks & Savings Institutions and Conference on Credit Unions in Washington, D.C. on steps that should be taken in advance of the commencement of negotiations and continuing through the signing and closing of a transaction. The presentation also included a discussion of the current regulatory climate with regard to M&A with an emphasis on hot button issues and potential regulatory threats to the successful and timely completion of a transaction and discussed non-traditional buyers (such as credit unions and investor groups).

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Luse Gorman Served as Legal Counsel to Land of Lincoln Credit Union in its Acquisition of Williamsville State Bank & Trust

September 2, 2026

On September 1, 2026, Land of Lincoln Credit Union (“LLCU”), Decatur, Illinois, completed its purchase of substantially all the assets and assumption of substantially all the liabilities of Williamsville State Bank & Trust, Williamsville, Illinois, the wholly-owned subsidiary of WSB Financial, Ltd. Following the completion of the transaction, LLCU has approximately $500 million in assets and 15 branch locations across Illinois.

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