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Hedgehog Intelligence | Prepared by PolicySight

Policy & Stakeholders

Texas: merger planning and authority

Alamo City → TAP leads a selective review of merger assumptions under the amended Texas framework.

Final rule · Effective August 27, 2026

Amended 7 TAC §91.1003: the Texas credit union merger framework

The amended framework raises the transparency bar for Texas credit union mergers before a member vote. Alamo City → TAP is the lead application under it.

Verified law / formal authority

The Texas Credit Union Commission adopted amendments to 7 TAC §91.1003, effective August 27, 2026. The framework requires current and combined financial information, net-worth information, credit-loss allowance analysis, changes to products/services, branches, advantages/disadvantages and other required plan information.

Member materials include required financial and compensation-related disclosures. Merger inducements are prohibited. The Commissioner has defined review / approval authority; preliminary or conditional approval is distinct from final merger steps.

Business implications

When two institutions need to reconcile different balance sheet assumptions under the amended disclosure framework, the financial case for the combination faces closer scrutiny. That creates a bounded merger planning conversation.

No Texas merger compliance assurance, Department or Commission endorsement, automated member approval, guaranteed merger outcomes or known Hedgehog customer relationship is asserted.

Decision path

Alamo City → TAP: an October application under a newly amended merger framework creates a concrete question about capital, credit, deposits and funding assumptions. Application is not approval or completion.

Texas merger decision path

  1. 1
    Institution decision

    Boards agree in principle

    Boards decide to pursue merger. This is an institution decision, not an approval or regulator instruction.

    Business implications: A bounded conversation may clarify which assumptions actually differ before any product evaluation.

  2. 2
    Verified law / formal authority

    Notify Commissioner and prepare the plan

    The merging state chartered credit union notifies the Commissioner and prepares the merger plan/application under the Texas framework.

    Business implications: Traceable assumptions may support planning, not filing compliance.

  3. 3
    Verified law / formal authority

    Reconcile current and combined financial assumptions

    Required plan elements include current and combined financial information, net worth, credit-loss allowance analysis, products/services, branches, advantages/disadvantages and other required information.

    Business implications: Model choice and traceability may help reconcile different balance sheet assumptions; specific workflow support would be confirmed directly.

  4. 4
    Verified law / formal authority

    Department / Commissioner review

    Department / Commissioner reviews, requests information, publishes notice and may provide preliminary or conditional approval where applicable. This is distinct from final approval.

    Business implications: Auditability is potential analytical support only; Hedgehog does not provide or guarantee regulatory approval.

  5. 5
    Verified law / formal authority

    Member information and vote

    Members receive required financial and compensation-related disclosures and vote where member approval is required. Merger inducements are prohibited.

    Business implications: Planning assumptions may inform institution deliberation; no automated member approval is claimed.

  6. 6
    Verified law / formal authority

    Final approvals and legal combination

    Commissioner and other required regulator(s) complete final approval / legal combination steps. The exact sequence across multiple regulators remains unverified for this transaction.

    Business implications: No approval engine or legal-completion capability is asserted.

  7. 7
    PolicySight interpretation

    Integrate, then review actual combined results

    The surviving institution integrates balance sheet, products, members, operations and assumptions. PolicySight interpretation: compare actual combined results against the merger plan; this is not a newly imposed rule requirement.

    Business implications: Comparing expected results with actual results may fit a bounded planning conversation after the combination, subject to product confirmation.

What happens next

Watch transaction status, the applicable transition guidance and how combined plan assumptions are reconciled. If existing advisers and models already answer the question, the fit is limited. No transaction specific approval sequence or integration date is inferred.

Recommended focus: a bounded merger planning use case

Affected institutions

Texas state chartered credit unions operate within the amended merger framework. This is a representative set from the Department's April 2026 charter list, not a claim that any of them is in an active merger.

Cases & activity

Q2 2026 financials are distinct from filing dates and the August 27 rule effective date. Verified ratios alone do not establish unsafe conditions, distress, a forced merger or legal undercapitalization.

Featured Texas caseApplication received, not approved or completed

Alamo City → TAP

Capital and credit assumptions · Survivor: Texas Association of Professionals Federal Credit Union (TAP)

Application received:
October 2026
Publication notice
CUD said it would be published October 30, 2026

Application received after the amended rule became effective. The rule is not asserted to have caused the merger. Neither approval nor completion is established.

PolicySight view

The two institutions enter the proposed combination with sharply different capital and credit profiles. The strongest question is how the combined plan reconciles net-worth targets, credit assumptions, funding, and member economics.

Decision consideration

Watch which capital, credit loss, deposit and funding assumptions change most when Alamo City is modeled inside TAP's surviving balance sheet.

Q2 2026 financials

Alamo City Credit Union

Texas state chartered

Assets
$8,750,960
Loans
$6,375,826
Shares / deposits
$8,294,780
Loan / share
About 76.87%
Net worth ratio
5.16%
Delinquency
3.04%
Members
958
Texas Association of Professionals Federal Credit Union (TAP)

Federal

Assets
$29,617,380
Loans
Not independently reproduced
Shares / deposits
$24,666,567
Loan / share
Not independently reproduced
Net worth ratio
15.73%
Delinquency
0.08%
Members
1,318

Exact Q2 loan balance was not independently reproduced in the research pass. No balance or loan/share ratio is invented.

Figures are supplied research from the listed reporting sources. Loan/share ratios are approximate. No current-quarter results, legal capital classification or software need is inferred.

Comparison before the ruleUnder consideration

Southern Star → BP FCU

Funding, liquidity and loan mix · Survivor: BP Federal Credit Union

Filing:
August 19, 2026

Filing predates August 27, 2026. Do not assume the amended rule applies without transition guidance. Application is not approval or completion.

PolicySight view

The key contrast is funding and loan mix. BP had a much higher loan-to-share position than Southern Star, so combined liquidity, deposit, and portfolio assumptions are more useful than a generic capital story.

Decision consideration

Watch how the combined institution's funding, liquidity and loan mix assumptions change when Southern Star's lower loan-to-share profile is absorbed into BP.

Comparison before the ruleProposed merger comparison

My Credit Union → Texas Trust

Scale and integration planning · Survivor: Texas Trust Credit Union

Application received:
May 20, 2026
NCUA vote listing:
August 17, 2026 listed member vote; result not established

Application and listed vote predate August 27, 2026. Comparison case, not a new-rule case; approval and completion are not established.

PolicySight view

This is primarily a scale and integration planning case. Texas Trust was roughly 36 times larger by assets, so product, branch, member, funding, and operating assumptions may matter more than capital remediation.

Decision consideration

Watch which assumptions from My Credit Union materially change when they are incorporated into a much larger Texas Trust operating and balance sheet model.

Bank M&A activity, separate authority

Bank mergers under Texas Department of Banking and Federal Reserve authority. This is broader Texas activity, separate from the credit union commissioner's merger authority under §91.1003.

Merged effective February 1, 2026

Texas Partners Bank → Prosperity Bank

Bank merger recorded by the Texas Department of Banking.

Merged effective March 1, 2026

Peoples Bank → Cornerstone Capital Bank, SSB

Bank merger recorded by the Texas Department of Banking, with Federal Reserve approval background.

Stakeholders & authority

Texas authority

Separate bank, savings bank and credit union decision systems. Appointment, governance, supervision, member decisions and merger approval are distinct. No personal policy position or transaction specific assignment is inferred.

153 named stakeholders · 27 bodies · 186 memberships / staff records

Authority lane 1

State-bank policy and supervision

Finance Commission → Banking Commissioner → TDB Bank & Trust Supervision → regional, review and specialist staff

Authority lane 2

Savings-bank policy and supervision

Finance Commission → SML Commissioner → Thrift Regulation → state savings bank

Authority lane 3

Credit union policy and supervision

Credit Union Commission → Credit Union Commissioner → CUD supervision and examination

Authority lane 4

Legislation and appointments

House PIFS; Senate Business & Commerce referral context; Governor appointments → Senate Nominations → full Senate confirmation

House PIFS has direct jurisdiction. Senate Business & Commerce is a verified referral lane, not universal exclusive bank or credit union jurisdiction.

Authority lane 5

SDSI accountability, procedure and cross-cutting enforcement

Commission budget approval; conditional legislative reporting and audit; State Auditor / LAC; TREO recommendations; Texas Register procedure; OAG where applicable

Trace a Texas decision path

14 processes · 55 supplied stages. Bank and savings-bank paths are additional decision-intelligence lanes, not current customer opportunities.

Texas decision process

State bank supervision / examination

  1. 1
    Finance Commission

    Ongoing

    Formal step / government action where applicable
    Sets policy and governance framework for TDB.
    Institution decision
    System-level governance
    Business implications
    Commission does not conduct bank examinations itself.
    Official page at fc.texas.gov (opens in a new tab)
  2. 2
    Banking Commissioner

    Ongoing

    Formal step / government action where applicable
    Leads TDB and implements Commission policy.
    Institution decision
    Agency supervisory posture
    Business implications
    Formal agency executive authority.
    Official page at statutes.capitol.texas.gov (opens in a new tab)
  3. 3
    Bank & Trust Supervision

    Ongoing

    Formal step / government action where applicable
    Conducts prudential supervision and examinations.
    Institution decision
    Respond to supervisory findings and expectations
    Business implications
    Potential relevance to model governance, IRR, capital or liquidity depends on the actual supervisory issue.
    Official page at dob.texas.gov (opens in a new tab)
  4. 4
    Regional/review/specialist staff

    Institution-specific

    Formal step / government action where applicable
    Perform regional examination, review, IT-security and capital-markets work.
    Institution decision
    Address examination findings or risk questions
    Business implications
    Named staff roles are current public assignments, not proof of assignment to a particular institution.
    Official page at dob.texas.gov (opens in a new tab)

Authority relationships

219 explicit workbook edges: 180 membership records and 39 other verified records. Membership establishes the supplied role, not independent final authority. Combined body labels remain literal; no named holders are inferred.

  • verified

    Governor of Texas → appoints → Finance Commission members

    Finance Commission members are gubernatorial appointees; the Governor designates the presiding officer.

    appointments · Last verified November 5, 2026

    Official page at fc.texas.gov (opens in a new tab)
  • verified

    Texas Senate → advises and consents on → Governor appointments requiring confirmation

    Texas Constitution provides for Senate advice and consent on gubernatorial appointments.

    appointments; confirmations · Last verified November 5, 2026

    Official page at statutes.capitol.texas.gov (opens in a new tab)
  • verified

    Senate Nominations Committee → reviews → Gubernatorial appointments

    Current Senate committee handling nomination review before full Senate action.

    appointments; confirmations · Last verified November 5, 2026

    Official page at senate.texas.gov (opens in a new tab)
  • verified

    Finance Commission → appoints → Banking Commissioner

    Finance Code makes the Banking Commissioner chief executive of TDB, appointed by and serving at the will of the Finance Commission.

    agency leadership · Last verified November 5, 2026

    Official page at statutes.capitol.texas.gov (opens in a new tab)

Two commissions, separate prudential systems

Finance Commission → TDB and SML

Policy making and executive appointment governance for state banks and savings banks.

Credit Union Commission → CUD

Separate policy making and commissioner appointment governance for state chartered credit unions.

Industry influence, not government authority

These associations advocate for industry interests. They do not exercise state supervisory, rulemaking, merger approval or enforcement authority.

Policy watch

Current Commission rule activity and review processes. Proposed amendments are not adopted rules.

Final rule, effective August 27, 2026

§91.1003 merger and consolidation amendments

Implementation of the amended disclosure, board due diligence, merger-related financial arrangement, member information and commissioner approval framework.

Proposed March 27, 2026

§91.709 Member Business and Commercial Loans amendments

Proposed amendments listed by the Department. Not adopted; no rule change is claimed before adoption.

Proposed March 27, 2026

§91.714 Leasing amendments

Proposed amendments listed by the Department. Not adopted; no rule change is claimed before adoption.

Current review process

Periodic review of Credit Union Commission rules

The Department's periodic review process for Commission rules. A review process is not a rule change.

Agency planning context

Bank M&A planning context

The Texas Department of Banking's 2027-2031 strategic plan says bank merger and acquisition activity is expected to continue at a steady pace. Agency planning context, not a rule.