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July 11, 2023

Fact Sheet: The Review Process for Bank Mergers and Acquisitions Is Seriously Deficient, Allows Too-Big-to-Fail to Proliferate, and Fails to Protect Consumers

WASHINGTON, D.C.— Dennis M. Kelleher, Cofounder, President and CEO, issued the following statement in connection with the release of a fact sheet entitled “The Review Process for Bank Mergers and Acquisitions Is Seriously Deficient”:

“America’s Main Street families benefit from a diversified banking system, from community banks to regional banks to large banks.  Done right, bank mergers can be a healthy part of that system but, done wrong, they can be destructive and counterproductive.  Unfortunately, the current merger review process utilized by the Federal Reserve, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation (the Agencies) is seriously deficient. The Agencies must not continue the current process which impairs the viability of community banks, eliminates healthy competition, and creates gigantic too-big-to-fail banks.

“This insufficient merger review process, combined with other factors such as changes in laws and economic events, has contributed to massive consolidation in the banking industry over the last three-and-a-half decades. This consolidation has dramatically changed the landscape of the U.S. banking industry, reducing competition, concentrating risks, and increasing financial stability concerns. For example, the top four banks hold about 40% of all assets in the banking system and the top ten banks hold almost half of all deposits and loans. And in just the last three years, the three largest bank mergers since the 2008 Crash were approved by the Agencies.

“In our fact sheet, we detail how the Agencies must update their merger review process to more fully account for the risks to consumers, taxpayers, the financial system and stability, and, ultimately, the economy. Otherwise, this trend of increasing consolidation within the banking system will continue, which will result in more too-big-to-fail banks, financial crashes, and bailouts.”


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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