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October 14, 2022

Better Markets Welcomes Banking Agencies Increased Scrutiny of US Bancorp Merger, but More Must Be Done to Lower Systemic Risk

WASHINGTON, D.C.—Dennis Kelleher, President and CEO of Better Markets, issued the following statement upon the approval by the Federal Reserve and the Office of the Comptroller of the Currency in consultation with the FDIC (“banking agencies”) for U.S. Bancorp to acquire the U.S. operations of MUFG, which will make U.S. Bancorp the seventh largest U.S. bank:

“While the bank merger and acquisition approval process (‘merger process’) needs to be further strengthened, we applaud the Federal Reserve, OCC, and the FDIC (‘banking agencies‘) for their stricter scrutiny of the application of U.S. Bancorp (‘USB’) to acquire the U.S. operations of MUFG. The conditions put in place as part of the approval, particularly with regard to financial stability risks, are necessary and appropriate and make it clear that this was not the type of rubber-stamp review done for previous mega-mergers.

“Although US Bancorp is not a GSIB (‘global systemically important bank’), at a post-acquisition size of $699 billion in assets it still poses a material risk to the financial system and the economy. It must be appropriately regulated to eliminate that risk, which includes not allowing the bank to game the rules by hovering just below the $700 billion asset threshold to avoid heightened supervisory and regulatory standards. We welcome the banking agencies’ specific conditions and timelines designed to prevent that.

“Finally, while GSIB designation is critically important, it is an inadequate regulatory framework for addressing megabanks that pose a grave domestic threat, but not necessarily a global threat.  US Bancorp and numerous other so-called ‘regional’ U.S. banks are anything but regional: they are systemically important to the country as a whole and should be viewed as domestically systemically important banks or ‘DSIBs.’ Regulations for the biggest banks that threaten global financial stability are intended to address that global threat. Regulations for banks that pose systemic threats to the country if not the globe, DSIBs, must be regulated appropriate to their domestic threat.  The banking agencies actions today begin that process, but more work must be done.”


Better Markets is a non-profit, non-partisan, and independent organization founded to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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