66 unchanged sentences
The laws and regulations applicable to the Company and the Bank are subject to change.
−Removed: The likelihood and timing of any changes, and the impact such changes may have on the Company and the Bank, are difficult to predict, including any changes resulting from changes in the U.S.
+Added: The likelihood and timing of any changes, and the impact such changes may have on the Company and the Bank, are difficult to predict, including any changes resulting from the U.S.
presidential administration and U.S.
4 unchanged sentences
As a company listed on the NASDAQ Global Market, we are subject to NASDAQ standards for listed companies.
+Added: On June 29, 2025, the FTSE selected Citizens Community Bancorp, Inc.
+Added: for inclusion in the Russell 3000 ® Index as part of the 2025 annual reconstitution.
The Company is currently a “smaller reporting company” which allows us to provide certain simplified and scaled disclosures in our filings with the SEC.
We will remain a smaller reporting company for so long as the market value of the Company’s common stock held by non-affiliates as of the end of its most recently completed second fiscal quarter is less than $250 million, or as of the same period the Company’s annual revenues are less than $100 million and its public float is less than $700 million.
−Removed: In addition, we are currently considered a “non-accelerated filer” and will maintain that status for so long as the Company’s annual revenues are less than $100 million, and its public float is more than $75 million but less than $700 million.
Sarbanes-Oxley Act
13 unchanged sentences
Section 404 of SOX requires management of the Company to undertake a periodic assessment of the adequacy and effectiveness of the Company’s internal control over financial reporting.
−Removed: If the Company were to be classified as an “accelerated filer” rather than a “non-accelerated filer,” which we believe is probable in 2025, then we would become subject to the provisions of Section 404(b) of the Sarbanes-Oxley Act.
+Added: As an “accelerated filer,” we are subject to the provisions of Section 404(b) of the Sarbanes-Oxley Act.
Section 404(b) requires that an independent registered public accounting firm provide an attestation report on the Company’s internal control over financial reporting and the operating effectiveness of these controls, making the public reporting process more costly.
53 unchanged sentences
The DOJ withdrew its 1995 Bank Merger Guidelines and issued the 2024 Banking Addendum to its 2023 Merger Guidelines.
−Removed: The DOJ clarified that it will assess competition considerations in connection with bank and bank holding company mergers using its 2023 Merger Guidelines, which is the general merger review framework the DOJ now uses to evaluate transactions in all segments of the economy, and the 2024 Banking Addendum.
−Removed: The 2024 Banking Addendum provides guidance on how the DOJ will assess competition in the context of bank and bank holding company mergers.
−Removed: An analysis under the 2023 Merger Guidelines and 2024 Banking Addendum may include consideration of theories of harm and relevant markets not considered under the 1995 Bank Merger Guidelines, which focused primarily on concentrations of deposits and branches.
−Removed: Whether and how the guidance might be further changed or interpreted by the new administration is uncertain.
−Removed: Pause on Major Federal Reserve Rulemaking
−Removed: On February 28, 2025, Michael Barr stepped down as vice chair of supervision of the Federal Reserve.
−Removed: The Federal Reserve stated that it will not issue any major rulemaking until a new vice chair for supervision is confirmed by the U.S.
+Added: The DOJ clarified that it will assess competition considerations in connection with bank and bank holding company mergers using its 2023 Merger Guidelines, which is the general merger review framework the DOJ used to evaluate transactions in all segments of the economy, and the 2024 Banking Addendum.
+Added: The 2024 Banking Addendum provided guidance on how the DOJ would apply heightened scrutiny to assess competition in the context of bank and bank holding company mergers.
+Added: In May 2025, the FDIC rescinded its 2024 policy statement on bank merger review and reinstated prior guidance.
+Added: The OCC also rescinded the 2024 policy statement and reinstated regulatory provisions providing for expedited processing of bank mergers under its pre-2024 policies.
+Added: The current administration is seeking to implement a regulatory reform agenda that is significantly different than that of the prior administration, impacting the rulemaking, supervision, examination and enforcement priorities of the federal banking agencies.
+Added: We may be required to implement different compliance procedures and modify our policies and activities to comply with changes set forth by the current administration.
+Added: This may cause us to incur additional costs and expenses, and dedicate additional resources, to achieve compliance with any changes from the current administration, which can impact our financial condition and the results of our operations.
Bank Regulation
103 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.