Board of Governors of the Federal Reserve System

Bank Applications and M&A

The Federal Reserve reviews applications submitted by BHCs, SMBs, SLHCs, FBOs, and other entities and individuals for approval to undertake various transactions, including mergers and acquisitions (M&A), and to engage in new activities.²⁰

Overview of Activity

In 2025, the Federal Reserve reviewed 942 applications, an increase from the 807 applications reviewed in 2024, and 752 in 2023 (table 3). Despite the increased volume, the average and median number of days to act on an application was slightly lower during 2025 compared to 2024.²¹

Table 3. Dispositions and processing times of all applications, 2023–25

Mergers and Acquisitions

There were 145 total approved M&A applications in 2025, compared with the 99 in 2024 (table 4).²² M&A applications accounted for 16.4 percent of total approved applications in 2025, higher than both 2023 and 2024.

Table 4. M&A applications, dispositions, and processing times of all applications, 2023–25

Average processing time for M&A applications decreased to 85 days in 2025 from 101 days in 2024. M&A applications are generally more complex than other applications because they often require review of more than one banking organization. As a result, M&A applications often take more time to process.

A significant number of application types are subject to public notice and comment (table 5).²³ In instances where the Federal Reserve receives adverse public comments, additional time is often needed to provide the applicant with the opportunity to respond to the comments and for the Federal Reserve to evaluate the comments and the applicant's response. In most cases, applications subject to a timely and substantive adverse public comment are acted upon by the Board, which also can result in delayed processing time.²⁴

Table 5. M&A approved applications, volume and processing times by whether they received adverse public comments, 2023–25

Applications Requiring Board Action

Of applications dispositioned by the Federal Reserve in 2025, 22 required action by members of the Board (table 6). Twenty-one of those were approvals and one was a denial.²⁵

By their nature, applications that require action by members of the Board typically require additional review, which may result in materially longer processing time. The average and median processing times for all application types acted on by the Board in 2025 was 140 days and 112 days, respectively, much shorter than the 215 days and 153 days, respectively, for 2024. Similarly, the average and median processing times for M&A applications acted on by the Board was 162 days and 128 days, respectively, for 2025 versus 259 days and 165 days, respectively, for 2024.

Table 6. Applications acted on by the Board, 2023–25

Community Banking Organizations

Table 7 provides the volume and processing times of the application types most commonly submitted by small and large CBOs.

Table 7. Applications from CBOs, volume and processing times (days) of approved applications, 2023–25

Pending Applications

There were 118 applications under review as of year-end 2025 (table 8).²⁶ The lower number of pending cases at year-end 2025 compared to 2024, despite an overall higher volume of cases, is in part due to efforts to process cases more quickly, leaving less currently pending.

Table 8. Applications under review (pending), as of year-end 2023–25

 

References

 

 20. Information on applications and M&A activity was previously published in the Semiannual Report on Banking Applications Activity, which is no longer being separately published. See https://www.federalreserve.gov/publications/semiannual-report-on-banking-applications-activity.htm. Return to text

 21. The processing times reflected are the times from receipt of the final application until the application is dispositioned (e.g., approved or withdrawn). The processing times 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. Return to text

 22. M&A applications include applications filed by BHCs, SLHCs, or SMBs that seek approval to acquire an ownership interest in or to merge with another banking organization, as well as BHC and SLHC formations. Return to text

 23. Applicants are generally required to publish notice of applications that are subject to public comment in newspapers serving certain communities in which the applicant and target have operations. In addition, the Federal Reserve publishes notices in the Federal Register for certain types of applications and also posts the weekly H.2A report on the Board's website, which lists all applications that have been filed with the Federal Reserve that are subject to public comment. See https://www.federalreserve.gov/apps/h2a/h2aindex.aspx. These notices inform the public of the opportunity to submit written comments on the proposal. Return to text

 24. Provided the applications meet the statutory factors for approval, the Federal Reserve Banks can approve under delegated authority applications that do not receive any substantive adverse public comment; do not raise significant legal, policy, or supervisory issues; or otherwise are not required to be acted upon by the Board. See 12 CFR § 265.20. Return to text

 25. 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. See 12 CFR § 265.20(c), (e). Return to text

 26. Multiple long pending asset manager and commodities cases which remained outstanding at each of the year-ends reflected in the table materially impact both the volume of outstanding applications on those dates as well as the processing time durations. Return to text