Bank Applications and M&A
The Federal Reserve, in its role as a primary federal banking regulator, reviews applications submitted by bank holding companies (BHCs), state member banks (SMBs), savings and loan holding companies (SLHCs), foreign banking organizations, and other entities and individuals for approval to undertake various transactions, including mergers and acquisitions (M&A), and to engage in new activities.21
Overview of Activity
As reflected in the table below, the Federal Reserve approved 413 applications in the first half of 2025.22 As noted in the lower portion of the table, of those applications, 12 required approval by members of the Board. Nine of these 12 involved M&A transactions, including one M&A transaction whose application was submitted by a firm with greater than $100 billion. Overall, M&A applications accounted for 18.0 percent (74) of total approved applications in the first half of 2025.
Applications can require action by members of the Board for a variety of reasons, including receipt of an adverse public comment; the application exceeding certain competitive or financial stability thresholds; the presence of significant legal, policy, or supervisory issues; or the application containing other characteristics that would not permit action under authority delegated to the Reserve Banks by the Board.23 By their nature, such applications typically require additional review, which may result in materially longer periods of time for processing.
The processing times for applications in table 3 are the times from receipt of the application until the application is approved. The processing times shown below include any time between the receipt of application filing and when it is deemed complete, including time for the applicant to complete the record by responding to additional information requests. The periods would be longer if the starting date were the date on which an application was first discussed with the Board or a Federal Reserve Bank or the date on which the parties signed a definitive M&A agreement.
Table 3. All approved applications and processing times; Approvals acted on by Board Members
| 2022 | 2023 | 2024 | 2025:H1 | |
|---|---|---|---|---|
| All approved applications | 868 | 664 | 751 | 413 |
| Average processing days | 49 | 48 | 50 | 51 |
| Median processing days | 37 | 34 | 41 | 36 |
| All approved merger & acquisition applications | 155 | 96 | 99 | 74 |
| Average processing days | 87 | 81 | 101 | 99 |
| Median processing days | 48 | 49 | 58 | 60 |
| All approved applications acted on by Board members | 26 | 8 | 11 | 12 |
| Average processing days | 194 | 180 | 215 | 167 |
| Median processing days | 158 | 184 | 153 | 167 |
| Merger & acquisition applications acted on by Board members | 19 | 4 | 7 | 9 |
| Average processing days | 189 | 233 | 259 | 177 |
| Median processing days | 160 | 204 | 165 | 157 |
| Merger & acquisition applications acted on by Board members for firms greater than $100 billion | 3 | 1 | 1 | 1 |
| Average processing days | 306 | 364 | 98 | 393 |
| Median processing days | 346 | 364 | 98 | 393 |
Note: Since 2022, the Board's average time to approve a merger and acquisition application for firms greater than $100 billion has been 295 days. The one transaction approved in 2025 was a complex application involving the merger of two large financial organizations. Competitive considerations, the receipt of over 6,000 public comments, and coordination among various agencies contributed to an extended review period.
For further information on Federal Reserve applications activity, please see the webpage Semiannual Banking Applications Activities at https://www.federalreserve.gov/publications/semiannual-report-on-banking-applications-activity.htm.
References
21. The entities noted are required by statute to file applications relative to certain proposals pursuant to the Bank Holding Company Act (BHCA); the Bank Merger Act (BMA); the Change-in-Bank-Control Act (CIBCA); the Federal Reserve Act (FRA); section 914 of the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA); section 10 of the Home Owners' Loan Act (HOLA); the International Banking Act; and other provisions of law. For example, in addition to M&A and new activities, BHC applications can include, but are not limited to, change-in-control proposals, stock redemptions, and management changes. SMB applications can include, but are not limited to, establishment of new branches, public welfare investments, and acquisition of financial subsidiaries. Applications by individuals primarily involve change-in-control transactions. Return to text
22. The data presented in this section are derived from the Federal Reserve's electronic applications platform (FedEZFile). The data are subject to minor updates reflecting data corrections or other revisions to the input. As presented here, application is defined as one filing, which may have been submitted pursuant to multiple statutes. For example, an application could include the acquisition of a BHC, the merger of the target's subsidiary bank with the applicant's subsidiary bank, and the establishment of branches at the location of the target bank's branches. This one application includes filings under various regulatory statutes. Return to text
23. See 12 C.F.R. 265.20(c); and C.F.R. 265.20(e). Return to text