Statement of Governor Michelle W. Bowman on the proposed changes to the FR Y-3 and FR Y-3F

May 3, 2024

The proposed changes to the FR Y-3 and FR Y-3F include a requirement for an applicant to submit an integration plan at the time of the initial application. I encourage public feedback on this proposed requirement. Applications often include plans for integration, as this can factor into the consideration of an application's likelihood of approval. Depending upon how this requirement is implemented, it could result in significantly increased upfront costs and burdens for banks in preparing for and submitting applications for mergers and acquisitions.

It is important for industry participants to provide comment on changes to the bank merger process—including changes to application forms—especially since cost and timing implications could affect a bank's consideration of these transactions. Ultimately, while banks are mindful of and do plan for integration, my concern is that increased upfront requirements may lead to additional delays in processing applications. I encourage industry stakeholders to review and provide comment on the proposed changes.