The FDIC board today voted to bring back an independent office at the agency to oversee bank appeals of its supervisory decisions. In addition, the Office of the Comptroller of the Currency plans to explore similar reforms to its supervisory appeals process, according to Comptroller Jonathan Gould.
The FDIC last year proposed to eliminate the Supervision Appeals Review Committee and replace it with the independent Office of Supervisory Appeals. The agency eliminated the OSA in 2022 – not long after the office was formed as a replacement for SARC, which the American Bankers Association and others said was an ineffective vehicle for banks to challenge supervisory findings.
The finalized guidelines bring back the OSA but include changes from the original proposal. Among the revisions is a requirement that a panel of three officials consider each appeal, with one panelist required to have bank industry experience.
Before the vote, Gould – who serves on the FDIC board – said the OCC will be “following in the footsteps” of the FDIC and will propose its own appeals process reforms in the near future.










