Legal Update – OCC Announces Changes to Licensing Procedures and CRA Evaluations to Incorporate Debanking Reviews

September 15, 2025

On September 8, 2025, the OCC announced actions, including issuing two Bulletins, to “end the weaponization of the financial system” by “rooting out” activities that “unlawfully debank or discriminate against customers on the basis of political or religious beliefs, or lawful business activities.” Our Legal Update, available here, describes the OCC’s plan to start reviewing banks’ debanking practices in licensing application reviews and CRA evaluations, and the agency’s instructions to banks regarding responding to government information requests and preparing SAR filings. Our Legal Update also offers a number of tips for OCC-supervised institutions prepare for further scrutiny from the agency regarding this issue.

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Luse Gorman Served as Legal Counsel to Harborstone Credit Union in its Acquisition of SaviBank

September 10, 2025

On September 1, 2025, Harborstone Credit Union (“Harborstone”), Lakewood, Washington, completed its purchase of substantially all assets and assumption of substantially all liabilities of SaviBank, Mount Vernon, Washington, the wholly-owned subsidiary of Savi Financial Corporation, Inc. Following the completion of the transaction, Harborstone has approximately $2.7 billion in assets and 26 banking locations throughout Washington.

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Luse Gorman Served as Legal Counsel to Berkshire Hills Bancorp, Inc. in its Merger of Equals with Brookline Bancorp, Inc.

September 3, 2025

On September 1, 2025, Berkshire Hills Bancorp, Inc. (“Berkshire”), the holding company for Berkshire Bank, and Brookline Bancorp, Inc. (“Brookline”), the holding company for Brookline Bank, Bank Rhode Island and PCSB Bank, completed their previously announced merger of equals. Berkshire, now known as Beacon Financial Corporation, and Brookline Bank, now known as Beacon Bank & Trust, are the surviving entities. This all-stock transaction was valued, at announcement, at approximately $1.1 billion.

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