Federal Deposit Insurance Corporation proposes to establish an independent Office of Supervisory Appeals

The Federal Deposit Insurance Corporation has put forward a proposal to create a standalone Office of Supervisory Appeals to review and decide appeals of material supervisory determinations, replacing the current approach that relies on senior FDIC officials serving alongside other duties. The appeals process was first established in 1995 through the Supervision Appeals Review Committee (SARC), which typically consists of FDIC Board members and deputies who may have limited direct examination experience. A 2020 FDIC Board proposal to replace the SARC with an independent office became operational at the end of 2021 but was later disbanded before hearing an appeal. Under the new proposal, reviewing officials would be recruited externally and serve time-limited terms, with the office structured as a dedicated unit intended to be independent, consistent, and scalable if appeal volumes increase. Compared with the 2021 guidelines, the proposal would broaden the types of experience accepted for reviewing officials, while still requiring that at least one individual on any appeals panel have direct supervisory experience from a supervisory agency. The FDIC indicated it is seeking comments on the proposal.