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Proposed Amendments to FDIC Guidelines for Appeals of Material Supervisory Determinations

Supervisory Guidance
July 15, 2025

Summary:

The FDIC is soliciting comment on a proposal to amend the agency’s Guidelines for Appeals of Material Supervisory Determinations (Guidelines). The proposal would replace the current Supervision Appeals Review Committee (SARC) with an independent, standalone office within the FDIC, known as the Office of Supervisory Appeals (Office). The Office would serve as the final level of review of material supervisory determinations made by the FDIC. These changes will facilitate a robust, independent supervisory appeals process that would be consistent over time.

A copy of the Notice (PDF) can be found on the FDIC’s website.

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

Highlights:

  • The Office would be independent of the Divisions that make supervisory determinations. An institution would be able to appeal a material supervisory determination to the Office after the appropriate Division Director’s review of the material supervisory determination.
  • The Office would be 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. At least one reviewing official on a panel would be required to have bank supervisory experience. Reviewing officials would be subject to confidentiality and conflict of interest requirements.
  • The Office would make an independent supervisory determination without deferring to the judgements of either party, subject to the reasonableness of and the support for the positions advanced.
  • The Office would be fully operational upon or following issuance of the final revised Guidelines. The FDIC plans to initiate the hiring process in the near term so that the Office may be fully operational as soon as the final Guidelines are in place. Until then, the current Guidelines would continue to apply, and all appeals of Division Directors’ decisions would be reviewed by the SARC.
  • Comments on the proposal are due 60 days after publication in the Federal Register.
FIL-31-2025
Attachment(s)
Notice regarding Proposed Amendments to FDIC Guidelines for Appeals of Material Supervisory Determinations
Contact(s)
Legal Division

Last Updated: July 15, 2025