The American Bankers Association yesterday welcomed the Federal Reserve’s recently proposed amendments to its appeals process guidelines and urged more action by the Fed to enhance its exam appeals process. “[F]rom 2001 to 2012, only 25 appeals were received by the Federal Reserve System, and only two of these appeals reversed the findings of the bank examiners,” ABA said. “This lack of confidence in the appeals process is a problem that needs to be addressed.”
Specifically, ABA urged the Fed to make matters requiring attention eligible for appeal, to provide clear guidance on standards of review, to protect confidentiality in appeal decisions and to enhance the powers of the Fed’s ombudsman.
The proposal is the first set changes considered by the Fed since adopting its appeal guidelines in 1995. In particular, the Fed is considering removing one level of appeal, addressing a timing conflict for appeal determinations that trigger prompt corrective action and creating a consistent standard of review for appeals. For more information, contact ABA’s Shaun Kern.