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Financial Institution Letter
FDIC Proposes Changes to Its Supervisory Appeals Process


The FDIC is seeking comments on proposed amendments to its Guidelines for Appeals of Material Supervisory Determinations (Guidelines). The proposed amendments are intended to enhance the independence of appeals decisions and to clarify the procedures and timeframes that apply to appeals when the FDIC is taking a formal enforcement action. Comments on the proposed amendments to the Guidelines will be accepted until October 20, 2020.

A copy of the Notice and Request for Comment can be found on the FDIC’s website

Statement of Applicability to Institutions with Total Assets Under $1 Billion: This Financial Institution Letter (FIL) applies to all FDIC-supervised institutions.


  • The proposal would replace the Supervision Appeals Review Committee (SARC) with an independent, standalone office within the FDIC, known as the Office of Supervisory Appeals (Office).
  • The Office would be independent of the Divisions that have authority to issue material supervisory determinations, while still operating within the FDIC.
  • To promote the independence of the Office, the FDIC anticipates recruiting externally and employing reviewing officials on a part-time or intermittent, time-limited basis. Reviewing officials may serve on term appointments.
  • The proposal also would modify the procedures and timeframes for when determinations underlying formal enforcement-related actions may be appealed.
  • Comments on the proposed amendments to the Guidelines will be accepted until October 20, 2020.


FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
Compliance Officer
Chief Lending Officer

Last Updated: August 21, 2020