OBL Submits FDIC Comments Opposing Proposed Hicksville Bank Acquisition

07/08/26

Last Wednesday, the Ohio Bankers League submitted formal comments to the Federal Deposit Insurance Corporation opposing the proposed transfer of substantially all of the assets and liabilities of The Hicksville Bank to Interra Credit Union, an Indiana state-chartered, privately insured credit union.

This is an important moment for Ohio's banking industry, and OBL has been fully engaged.

From the outset, our concern has been straightforward: this transaction is not a routine bank merger or ordinary market consolidation. It would result in a healthy, tax-paying, FDIC-insured Ohio state-chartered community bank being absorbed by an out-of-state, tax-exempt credit union that is not federally insured. That raises serious legal, regulatory, depositor protection, community impact, and public policy issues that deserve close scrutiny from every regulator involved.

Our FDIC comment letter focused on the reasons the application should be denied under the actual legal and regulatory framework governing the transaction. Most importantly, OBL argued that Ohio law does not authorize an Ohio state-chartered bank to transfer substantially all of its assets and liabilities to a credit union. Ohio's bank asset-transfer statute identifies the types of institutions that may be counterparties to these transactions. Credit unions are not included. A general parity or "wild card" statute should not be used to rewrite that specific statutory framework.

We also highlighted the impact on depositors. Hicksville Bank customers currently hold deposits at an FDIC-insured Ohio bank. If the transaction is approved, those customers would no longer hold deposits at an FDIC-insured bank, but instead would become members of a privately insured credit union. That is not a technical change. Deposit insurance goes to the core of consumer confidence, and customers deserve clear, prominent, and meaningful disclosure before any such change occurs.

The comments also raised concerns for local governments and public deposit relationships. Banks play a central role as public depositories for Ohio political subdivisions. Credit unions do not occupy the same role under Ohio law. The proposed transaction could therefore disrupt local public deposit relationships and reduce options for communities that rely on local banking partners.

OBL further addressed field-of-membership issues, noting that the FDIC should require a clear showing that Hicksville customers can lawfully be served by the resulting credit union structure. Regulators should not assume that every bank customer, business customer, municipal customer, or account relationship fits neatly into a credit union field of membership.

In addition, our comments emphasized that the transaction would remove the affected communities from the Community Reinvestment Act framework. Credit unions are not subject to CRA. Voluntary community service, while valuable, is not the same as enforceable statutory accountability.

This work is part of a broader OBL advocacy effort. We have engaged with the FDIC, the Ohio Department of Commerce, the Division of Financial Institutions, the Ohio Banking Commission, legislators, and other stakeholders to ensure the full implications of this transaction are understood.

The Hicksville transaction is about more than one bank. It is about the integrity of Ohio's banking laws, the strength of the Ohio bank charter, depositor protection, and the long-term future of community banking in this state.

OBL will continue to advocate aggressively and thoughtfully on behalf of Ohio's banks, their customers, and the communities they serve.

To read the full comment letter, please click HERE.