An independent supervisory appeals process at the Office of the Comptroller of the Currency would serve as a crucial backstop to support and promote fair and consistent supervision, the American Bankers Association said today.
The OCC in February proposed a new rule to make several revisions to its supervisory appeals process, including the creation of a new board to review appeals and a new “de novo standard of review” that “does not defer to the previous decision but freely considers the matter anew.”
In comments to the agency, ABA said it strongly supports the proposal. Among other things, the association recommended staffing the appeals board with independent, term appointees; establishing a pool of appointees to select three members to serve on an appeals board panel; and establishing due-process protocols if the comptroller overturns any appeals board decision.
