Recently, the Board of Governors of the Federal Reserve System issued guidance, which discusses various issues that may prevent the Federal Reserve from acting favorably on applications and notices submitted by banking organizations.1 In addition, the guidance describes the Federal Reserve’s approach to processing applications and notices that present such issues and provides relevant statistics for the period 2009 to 2012.
According to the guidance, to date, when Federal Reserve staff identify a problematic issue relating to an application or notice filed by a financial institution,2 they have typically informed the applicant or notificant of the issue and requested additional information. If the issue cannot be resolved during the review process and the staff are prepared to recommend that the proposal be denied, the general practice has been to provide the filer the option to withdraw the application or notice.
