Federal Deposit Insurance Corporation activates independent Office of Supervisory Appeals and expands appeal rights

The Federal Deposit Insurance Corporation has made its standalone Office of Supervisory Appeals fully operational, bringing revised guidelines for appeals of material supervisory determinations into effect. The office replaces the Supervision Appeals Review Committee as the final level of review and applies to all FDIC-supervised financial institutions. Institutions may appeal to the office after review by the appropriate division director. Three-member panels will include at least one official with bank supervisory or examination experience and at least one with industry experience, subject to confidentiality and conflict-of-interest requirements. Panels will make independent determinations without deferring to either party, and the revised framework allows the facts underlying certain proposed or pending enforcement actions to be considered on appeal, although formal enforcement actions themselves remain outside its scope.