The Federal Deposit Insurance Corporation (FDIC) Board is considering finalizing guidelines to establish an independent, standalone Office of Supervisory Appeals, intended to review and adjudicate supervisory appeals through officials hired externally whose sole role would be handling appeals. The final guidelines are described as largely consistent with the July 2025 proposal, with targeted changes responding to issues raised by commenters. Under the draft final approach, three-member panels reviewing material supervisory determinations would be required to include at least one reviewing official with bank supervisory or examination experience and at least one reviewing official with industry experience. The guidelines would also broaden institutions’ appellate rights by permitting appeals in certain situations where a formal enforcement action is proposed or pending, bringing the facts and circumstances underlying a proposed formal enforcement action into scope under specified conditions. If the guidelines are finalized, the Office would move toward becoming operational.
Federal Deposit Insurance Corporation 2026-01-22
Federal Deposit Insurance Corporation considers final guidelines for Office of Supervisory Appeals adding industry expertise and expanding enforcement-related appeal rights
The Federal Deposit Insurance Corporation (FDIC) Board is considering finalizing guidelines to establish an independent Office of Supervisory Appeals to review supervisory appeals, with panels including officials with bank supervisory and industry experience. The guidelines would expand institutions' appellate rights to include appeals in situations involving proposed or pending formal enforcement actions.