FDIC Federal Register Citations

I am writing in reference to the proposed rule changes in the Guidelines for Appeals of Material Supervisory Determinations. As is, before any changes, banks have little leverage in the appeals process. These proposed changes will only make it worse. And making changes based on the anti-bank mentality of other agencies should never be grounds for the FDIC to further reduce the rights of the banks it supervises.
The FDIC, much like the IRS, the EPA and other self-monitored government agencies, has set itself up as judge and jury over the banking industry. While there is a valued place in the regulatory process for the FDIC, there also needs to be an effective and non-biased appeals process for banks. It matters little what FDIC employees make up the SARC, they are still FDIC employees. So how independent can they possibly be?
This proposal to further reduce the provisions of, and ability to, appeal FDIC supervisory determinations is completely over-reaching, and should not be enacted into law.

Joe Wachtel - President
Monitor Bank
PO Box 98
Big Prairie, Ohio 44611
330-496-2981