US bank M&As: Model risk management and regulatory strategy

United States (US) banks announced 124 merger and acquisition (M&A) deals in 2025. Several of these were among the largest bank acquisitions on record, reflecting renewed industry confidence.

A notable enabler in the regulatory backdrop has been a shift toward restoring procedural predictability in the M&A process. In May 2025, the Office of the Comptroller of the Currency (OCC) issued an interim final rule rescinding the 2024 final rule (Business Combinations Under the Bank Merger Act) related to its regulations for business combinations involving national banks and federal savings associations, and an accompanying policy statement. This was done to reduce administrative burden and uncertainty in the Bank Merger Act application process by introducing streamlined and expedited procedures.

Parallelly, the Federal Deposit Insurance Corporation (FDIC) moved in 2025 to rescind its 2024 merger policy statement and reinstate the pre-2024 policy. The FDIC explained that the 2024 policy had added “considerable uncertainty” to the merger application process. These changes do not reduce supervisory expectations but improve clarity around the process.

As part of its merger review process, the FDIC evaluates the effectiveness of an acquirer’s risk-based programs to combat money laundering and financing of terrorism (the Bank Merger Act).