FDIC Appeals Process

FDIC has updated its guidelines for appeals of material supervisory determinations. See FIL-113-2004. The guidelines lay out a clear process and timeline for appeals. Banks should begin with their examiner and district office before filing a formal appeal.

While the appeals process deals with supervisory determinations, there are several aspects of compliance programs that could be affected by the appeal. These include CRA ratings, consumer compliance ratings, and Regulation Z restitution.

The appeals process cannot begin until the bank has received the report of examination. The bank then has 60 days to file an appeal with the Director of the Division of Supervision and Consumer Protection. If not satisfied with that outcome, the bank can then appeal to the Supervision Appeals Review Committee (SARC) within 30 days of the decision.

Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 12, 11/04