If you or someone within your organization file federal regulatory applications, be aware that some recent changes have been made to various forms.  Filing an outdated application or notification could cause delayed acceptance, processing and/or action of the filing by your federal regulators.  In mid-2018, revisions were made to bank and bank holding company interagency applications and notifications.  Recent changes have also been made to various applications and notifications specific to the Board of Governors of the Federal Reserve System (“the Fed”). 

The revisions made to the various forms range from relatively minor, to significant new requests.  The forms, listed below, have expiration dates which typically stretch out approximately three years from the time the forms are made available, though each agency has differing expiration dates.  While the expiration dates for the forms are nothing new, it has been some time, several years in fact, since significant changes were made to the interagency forms.

The recently revised interagency forms, which are filed with the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and the Fed, include:

  1. Interagency Bank Merger Act Application
  2. Interagency Notice of Change in Control
  3. Interagency Notice of Change in Director or Senior Executive Officer
  4. Interagency Biographical and Financial Report 

The applications/notifications specific to the Fed that have recently been updated include:

  1. FR Y-3 (Application to Become a Bank Holding Company and/or Acquire an Additional Bank or Bank Holding Company)
  2. FR Y-3N (Notification to Become a Bank Holding Company and/or Acquire an Additional Bank or Bank Holding Company)
  3. FR Y-4 (Notification by a Bank Holding Company to Acquire a Nonbank Company and/or Engage in Nonbanking Activities) 

The next time your organization needs to file one of these forms, we suggest retrieving the latest version from the appropriate regulatory agency’s website to ensure the most recent form is completed and filed.

If you have any questions regarding this article, or regulatory filings in general, please contact Kyle Shadid at (501) 374-2600 or at kshadid@ddfconsulting.com.