Bank Change of Control Application

The Change of Control Application process for buying a bank is similar to that of starting a de novo. The organizing group must develop a detailed business plan, with public and confidential sections, and submit that plan with the Change of Control Application to the regulating agency (the State, OCC, OTS, or the Federal Reserve. The business plan will:

  • Define what you want the bank to continue doing, as well as what you are going to change about the existing bank's operations.
  • Address the Community Reinvestment Act (CRA policy), which indicates how the bank is and will continue to serve the needs of the community.
  • Detail the bank's financial plan. The financial section identifies how the bank can survive in our current economy; the regulators evaluate the financial plan to determine if the bank can stay profitable in the following three - five years, or stay profitable through another economic crisis, after the change of control.
  • Include identity and financial information on organizers. All individuals involved must be fingerprinted and must complete an InterAgency Biographical and Financial Report (IBFR).
  • Include any and all other information. The regulators don't like surprises; this is where you tell all about what your short term and long term plans are - nothing is hidden!

The final application will be roughly 2200+ pages and weigh about 150 pounds with all copies. It will cost several hundreds dollars to ship overnight!