In a move that could reshape the financial services landscape, President Donald Trump has revoked a 2021 Biden-era executive order designed to tighten oversight of mergers and acquisitions. While the headlines center on banks, credit union executives would be wise to read between the lines: the regulatory pendulum is swinging back toward easier consolidation — and the ripple effects won’t stop at Wall Street.

What Changed

The Biden policy, pushed through the Office of the Comptroller of the Currency (OCC), was crafted to curb “excessive consolidation” across industries, with banking singled out as a sector under heightened scrutiny. Among other steps, it:

• Removed the 15-day “automatic approval” policy for merger applications.
• Eliminated streamlined reviews for small-bank combinations.
• Imposed tougher standards for institutions with $50B+ in assets.

The idea was clear: mergers, especially among larger players, needed more guardrails to preserve competition and protect consumers.

Now, with Trump’s revocation, those guardrails are gone. The administration is signaling an “America First Antitrust” approach — shorthand for deregulation and a free-market lens. The OCC and FDIC had already started unwinding parts of the policy earlier this year, but Trump’s move makes the shift official.

Why It Matters for Credit Union Executives

At first glance, this is a banking story. But for credit union leaders, the implications are real:

• Competitive Pressure Will Rise. If regional and community banks find M&A pathways less encumbered, expect to see larger, more aggressive competitors in your markets. Credit unions already compete against scale; this accelerates that dynamic.
• Valuations Could Change. Looser approval standards may drive up the pace — and price — of acquisitions, particularly in markets where banks and credit unions overlap.
• Narrative Control Is Crucial. Policymakers are leaning into efficiency and growth. Credit unions must double down on telling the member-value story, lest the industry gets caught in the same “consolidation” critique banks face.
• Indirect Opportunity Exists. With regulators signaling less friction for consolidation, credit unions exploring bank acquisitions or strategic partnerships may find the environment more favorable — if NCUA maintains a consistent line.

The Bigger Picture

Credit union leaders have spent the past decade navigating a world where scale and technology are increasingly decisive. Trump’s rollback doesn’t change the cooperative mission, but it does alter the competitive terrain. If banks grow larger, more digitally capable, and more aggressive in local markets, credit unions need to be sharper than ever in leveraging their community roots, partnerships, and fintech integrations.

This isn’t a regulatory story to skim past. It’s a signal that the consolidation wave is gaining fresh momentum. Credit union executives should be asking: Are we prepared for the next five years of heightened competition — and do we have our own growth strategy ready to deploy?