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Appeals of Material Supervisory Determinations: Guidelines & Decisions

Supervision Appeals Review Committee - Decisions

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SARC Decisions 
Case No. & Date Subject Matter
SARC-2014-01 - 01/07/2014 - PDF Appeal of the written determination of the Director, DCP following review of two material supervisory determinations: the Compliance rating and CRA rating.
SARC-2013-01 - 08/30/2013 - PDF Appeal of determinations by the Director of RMS that (1) certain notes receivable issued by Holding Company to Subsidiary Bank were improperly accounted for and should be excluded from equity capital; and (2) that the affected Consolidated Report of Condition and Income (“Call Report”) should be amended.
SARC-2012-01 - 06/19/2012 - PDF Appeal of determinations by the Director of RMS that (1) a loan was properly classified as a Loss under the definition established by the FDIC’s Risk Manual of Examination Policies; and (2) the Bank’s acquisition and retention of certain real estate was an unauthorized equity investment of a type not permissible under section 24 of the FDI Act as implemented by Part 362 of the FDIC’s Rules and Regulations.
SARC-2011-01 - 08/12/2011 - PDF Appeal of CRA Rating
SARC-2010-07 - 03/31/2011 - PDF Appeal of CRA Rating
SARC-2010-04 - 09/07/2010 - PDF Appeal of rate restrictions under 12 C.F.R. § 337.6
SARC-2010-03 - 08/17/2010 - PDF Appeal of Capital, Asset Quality, Management, and Earnings Component Ratings and the Composite Rating
SARC-2009-04 - 03/25/2010 - PDF Appeal of loan classifications and the Capital, Asset Quality, and Composite ratings
SARC-2008-02 - 02/13/2009 - PDF Appeal CRA Rating
SARC-2008-01 - 04/30/2008 - PDF Appeal CRA Rating
SARC-2007-04 - 05/02/2008 Appeal of Compliance and CRA Ratings
SARC-2007-03 - 03/10/2008 Appeal of Compliance and CRA Ratings
SARC-2007-02 - 03/10/2008 Appeal of Compliance Report of Examination
SARC-2007-01 - 09/05/2007 Appeal of Component and Composite ratings
SARC-2006-01 - 11/14/2006 Appeal of Component and Composite ratings
SARC-2005-04 - 12/28/2005 Appeal of Component and Composite ratings
SARC-2005-03 - 11/10/2005 Appeal of Supervisory Determination Regarding the Development and Validation of a Credit Scoring Model.
SARC-2005-02 - 08/31/2005 Appeal of Consumer Compliance Rating and Composite CRA Rating.
SARC-2005-01 - 08/05/2005 Appeal of Asset Quality and Management Component Ratings and Composite Rating.
SARC-2004-03 - 06/15/2004 Appeal of CAMELS component ratings for capital, asset quality, and management; CAMELS composite rating; and adverse loan classifications.
SARC-2004-02 - 04/12/2004 Appeal of the CAMELS component ratings for asset quality and management; and CAMELS composite rating.
SARC-2004-01 - 01/04/2004 Appeal of adverse loan classifications.
SARC-2003-03 - 12/31/2003 Appeal of the CAMELS component ratings for asset quality and earnings; CAMELS composite rating; determination that Call Report amendments are required to properly reflect "other than temporary impairment" of equity securities; and adverse classification of certain assets.
SARC-2003-02 - 11/04/2003 Appeal of the examination findings that the bank, through its subsidiary, engaged in a pattern of practice or "overt discrimination."
SARC-2003-01 - 10/14/2003 Appeal of the CAMELS component ratings for capital, asset quality, and management; CAMELS composite rating; subprime designation of the credit card portfolio; substandard classification of residual interests; and "troubled condition" designation.
SARC-2002-01 - 05/02/2002 Appeal of the CAMELS component ratings for capital, asset quality, management, earnings, liquidity, and sensitivity to market risk; and CAMELS composite rating.
SARC-2001-02 - 08/03/2001 Appeal of CAMELS component ratings for management and capital; CAMELS composite rating; adverse classification of the subprime credit card portfolio, assessment that the ALLL was inadequate, apparent violations of Part 323 (Appraisals) and the BSA; and finding that certain internal controls were inadequate.
SARC-2001-01 - 05/22/2001 Appeal of the CAMELS component ratings for management, earnings, sensitivity to market risk, and asset quality; and CAMELS composite rating.
SARC-2000-03 - 12/15/2000 Appeal of the CAMELS component ratings for management, liquidity, and sensitivity to market risk; and CAMELS composite rating.
SARC-2000-02 - 12/01/2000 Appeal of the CAMELS component ratings for management and capital, CAMELS composite rating, adverse classification of the subprime credit card portfolio, assessment that the ALLL is inadequate, apparent violations of Part 323 (Appraisals) and the BSA, and the determination of inadequate internal controls.
SARC-2000-01 - 05/23/2000 Appeal of apparent violations of Regulation Z (Truth in Lending).
SARC-1999-07 - 12/10/1999 Appeal of the CAMELS component ratings for asset quality, management, liquidity, and sensitivity to market risk; CAMELS composite rating; apparent violation of Part 309 (Disclosure); and "troubled institution" designation.
SARC-1999-06 - 11/24/1999 Appeal of the Trust component ratings of management and compliance, and apparent violation of regulations governing the bank's employee stock ownership plan.
SARC-1999-05 - 09/13/1999 Appeal of the CRA rating.
SARC-1999-04 - 08/09/1999 Appeal of the CAMELS component ratings for capital and earnings, adverse classification of a finance company's entire loan portfolio, and assessment that the ALLL methodology and balance are inadequate. 
SARC-1999-03 - 05/12/1999 Appeal of the CAMELS component ratings for capital, asset quality, management, earnings, and sensitivity to market risk; CAMELS composite rating; adverse loan and ORE classifications, apparent violation of Part 362 (Bank Activities), and continuance of the Cease and Desist Order.
SARC-1999-02 - 02/04/1999 Appeal of the CRA rating and certain Compliance examination findings.
SARC-1999-01 - 02/04/1999 Appeal of the CAMELS component rating of management and CAMELS composite rating.
SARC-1998-07 - 09/22/1998 Appeal of Appeal of the CAMELS component rating of management, CAMELS composite rating, and continuance of a Memorandum of Understanding.
SARC-1998-06 - 07/28/1998 Appeal of an apparent violation of Regulation Z (Truth in Lending).
SARC-1998-05 - 07/17/1998 Appeal of the Information Systems composite rating and the Year 2000 assessment.
SARC-1998-04 - 06/02/1998 Appeal of apparent violations of Regulation Z (Truth in Lending).
SARC-1998-03 - 06/02/1998 Appeal of the CRA rating.
SARC-1998-02 - 03/12/1998 Appeal of the CAMELS component ratings of capital, liquidity, and sensitivity to market risk; CAMELS composite rating; and initiation of a Memorandum of Understanding.
SARC-1998-01 - 02/26/1998 Appeal of the CAMELS component ratings for capital, asset quality, management, earnings, and sensitivity to market risk; CAMELS composite rating; certain loan and ORE classifications, and continuance of a Cease and Desist Order.
SARC-1997-04 - 12/04/1997 Appeal of an apparent violation of Regulation Z (Truth in Lending) and corresponding restitution.
SARC-1997-03b - 10/10/1997 Appeal of apparent violations of Regulation Z (Truth in Lending); pattern or practice of violations.
SARC-1997-03 - 09/19/1997 Appeal of the CAMELS component ratings of asset quality and management; CAMELS composite rating; certain adversely classified assets; and assessment that the ALLL methodology is inadequate.
SARC-1997-02 - 09/19/1997 Appeal of the determination that subject preferred stock should be excluded from Tier 1 Capital.
SARC-1997-01 - 09/15/1997 Appeal of the CAMELS component ratings for capital, asset quality, liquidity, and management; the CAMELS composite rating; certain adversely classified assets; apparent violations of the Bank Secrecy Act (BSA) and Part 323 (Appraisals).
SARC-1996-07 - 12/06/1996 Appeal of the CRA rating.
SARC-1996-06 - 12/06/1996 Appeal of the CRA rating.
SARC-1996-05 - 09/27/1996 Appeal of the assessment that the ALLL methodology is inadequate.
SARC-1996-04 - 06/26/1996 Appeal of the CRA rating.
SARC-1996-03 - 03/22/1996 Appeal of apparent violations of Regulation O.
SARC-1996-02 - 02/29/1996 Appeal of an Other Real Estate (ORE) classification and continuance of the Cease and Desist Order.
SARC-1996-01 - 02/29/1996 Appeal of the CAMELS composite rating.
SARC-1995-08 - 12/19/1995 Appeal of the CRA rating.
SARC-1995-07 - 11/08/1995 Appeal of the formula classification of credit card receivables in accordance with the Uniform Policy for Classification of Consumer Installment Credit based on Delinquency Status.
SARC-1995-06 - 10/19/1995 Appeal of the Consumer Compliance rating.
SARC-1995-05 - 10/18/1995 Appeal of the CRA rating.
SARC-1995-04 - 10/04/1995 Appeal of the Consumer Compliance and the Community Reinvestment Act (CRA) ratings.
SARC-1995-03 - 08/25/1995 Appeal of a Call Report amendment requiring certain compensation paid to non-officer directors to be reported as dividends rather than bonuses.
SARC-1995-02 - 07/17/1995 Appeal of the CAMELS composite rating.
SARC-1995-01 - 07/14/1995 Appeal of apparent violations of Part 323 (Appraisals), State chattel property laws, and assessment that the ALLL is inadequate.


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