Citigroup and Wells Fargo are currently the only U.S. megabanks with sufficient room under the 10% national deposit cap to acquire a large regional bank, as JPMorgan Chase and Bank of America are restricted from such deals due to their existing deposit market share [1]. Despite this unique position and looser regulatory barriers under the Trump administration, neither Citigroup nor Wells Fargo has yet moved to make a major acquisition [1]. Wells Fargo CEO Charlie Scharf has indicated openness to a 'transformative deal,' while Citigroup CEO Jane Fraser has emphasized the bank's focus on organic growth rather than mergers and acquisitions [1].
The broader market context shows a significant decline in North American bank merger value, which fell by more than half in the first six months of 2026, according to EY [1]. However, Bain projects that industry consolidation will accelerate, with one to three new $1 trillion-plus megabanks expected by 2030 as the number of regional banks shrinks from 49 to as few as 30 [1]. Industry experts note that, after years of regulatory restrictions, large banks can now contemplate buying other lenders, including those with over $100 billion in assets [1].
Both Citigroup and Wells Fargo have recently cleared key regulatory hurdles that previously limited their growth—Citigroup through the lifting of consent orders and Wells Fargo through the removal of growth restrictions [1]. A large acquisition could provide Citigroup, which currently has about 650 U.S. branches, with a much-needed source of cheaper funding, while for Wells Fargo, it would add scale and cost-cutting opportunities to its already extensive branch network [1].
Analysts such as Chris McGratty from KBW highlight the urgency for consolidation, stating, 'There's a massive race for scale, and the shot clock is running. If you want to do something, this is the time to do it' [1]. Despite over 4,200 banks in the U.S., only a handful are considered viable acquisition targets for Wells Fargo or Citigroup due to size, branch network compatibility, and deposit quality requirements [1].
CONCLUSION
Wells Fargo and Citigroup are uniquely positioned to pursue transformative acquisitions in the current regulatory environment, though neither has acted yet. With industry consolidation expected to accelerate and analysts urging timely action, the market is closely watching these banks for potential moves that could reshape the U.S. banking landscape.
