In markets already designated as concentrated or uncompetitive, however, the current guidelines limit  See Conference of State Bank Supervisors, “2021 CSBS National Survey Shows Pandemic Impact on Community Banks,” news release, CSBS, https://www.communitybanking.org/news/csbs-national-surveyshows-pandemic-impact-on-community-banks. 9  - 11 prospective merger partners to out-of-market institutions—and acquisition offers from out-of-market banks in areas of declining population are exceedingly rare.
Fortunately, I think we have a unique opportunity today to address these issues. For example, the federal banking agencies and the Department of Justice have acknowledged in recent months that significant changes in the banking industry and in the competitive landscape for banking services will require us to rethink banking competition and mergers.