FDIC Office of Supervisory Appeals Is Operational

Summary:

On January 22, 2026, the FDIC Board approved revised Guidelines for Appeals of Material Supervisory Determinations (Guidelines), which established an independent, standalone Office of Supervisory Appeals (Office) to serve as the final level of review of material supervisory determinations made by the FDIC. The Office, which replaces the Supervision Appeals Review Committee, is now fully operational, and the revised Guidelines take effect today.

Office of Supervisory Appeals | FDIC.gov

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.

Highlights:

• The Office is independent of the Divisions that make supervisory determinations. An institution may appeal a material supervisory determination to the Office after the appropriate Division Director's review of the material supervisory determination.
• The Office is staffed by reviewing officials who have direct experience with the supervisory process, and may include former government officials, former bankers, and other former industry professionals. Each panel will include at least one reviewing official with bank supervisory experience and at least one reviewing official with industry experience. Reviewing officials are subject to confidentiality and conflict of interest requirements.
• The Office will make independent supervisory determinations without deferring to the judgments of either party, subject to the reasonableness of and the support for the positions advanced.
• In addition, institutions' appeal rights are now expanded to permit appeals in certain cases when an enforcement action is proposed or pending.