North Dakota Bankers
Extraordinary Leadership for North Dakota Banks

FDIC Reinstates Independent Supervisory Appeals Office

FDIC Reinstates Independent Supervisory Appeals Office

Posted: Jan 28 2026
The FDIC board has voted to bring back an independent office at the agency to oversee bank appeals of its supervisory decisions. In addition, the OCC plans to explore similar reforms to its supervisory appeals process, according to Comptroller Jonathan Gould.
 
The FDIC last year proposed to eliminate the Supervision Appeals Review Committee and replace it with the independent Office of Supervisory Appeals. The agency eliminated the OSA in 2022 – not long after the office was formed as a replacement for SARC, which the banking industry said was an ineffective vehicle for banks to challenge supervisory findings.
 
The finalized guidelines bring back the OSA but include changes from the original proposal. Among the revisions is a requirement that a panel of three officials consider each appeal, with one panelist required to have bank industry experience.
 
Before the vote, Gould – who serves on the FDIC board – said the OCC will be “following in the footsteps” of the FDIC and will propose its own appeals process reforms in the near future.
 
To read more, visit: https://bankingjournal.aba.com/2026/01/fdic-reinstates-independent-supervisory-appeals-office/
 

Designed and developed by Odney