FDIC Statement on Establishing Office of Supervisory Appeals

FDIC Speeches

Published January 22nd, 2026

Detected March 14th, 2026

Summary

FDIC Chairman Travis Hill announced final guidelines for the new Office of Supervisory Appeals. The office will provide an independent review of supervisory determinations, with modifications to panel composition and expanded appellate rights for institutions facing proposed enforcement actions.

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What changed

FDIC Chairman Travis Hill's statement outlines the final guidelines for establishing an independent Office of Supervisory Appeals. Key changes from the proposal include ensuring that review panels include at least one member with industry experience, in addition to supervisory or examination experience. Furthermore, the guidelines expand appellate rights to include certain cases where a formal enforcement action is proposed or pending, allowing for independent review of the underlying facts and circumstances.

These changes aim to create a more independent, apolitical, and consistent appeals process for financial institutions. Regulated entities should be aware of the expanded scope of appeals, particularly concerning proposed enforcement actions. While no specific compliance deadline is mentioned, the Office is expected to become operational soon, and institutions should prepare to utilize this new avenue for challenging supervisory determinations.

What to do next

Review the final guidelines for the Office of Supervisory Appeals.
Understand the expanded scope of appellate rights, including appeals related to proposed formal enforcement actions.
Prepare to utilize the Office of Supervisory Appeals for challenging material supervisory determinations.

Source document (simplified)

Statement by Chairman Travis Hill Guidelines to Establish the Office of Supervisory Appeals

Chairman Travis Hill Statement, Board Meeting January 22, 2026 On July 15, 2025, the FDIC Board of Directors approved a proposal to establish an independent, standalone Office of Supervisory Appeals. 1 As I noted at the time, the intent of the Office, which would be staffed by officials hired externally whose sole job would be reviewing and adjudicating supervisory appeals, is to promote an independent, apolitical, and consistent appeals process.

Today, the FDIC Board is considering finalizing the proposal. The final guidelines would be largely consistent with the proposal, with certain modifications in response to issues raised by commenters.

One change involves the composition of the panels that would review material supervisory determinations. In addition to providing that each three-member panel include at least one reviewing official with bank supervisory or examination experience, the final guidelines would provide that at least one reviewing official will have industry experience. Including individuals with industry experience will broaden the perspectives reflected on a panel and allow the appellate process to benefit from a diversity of views, while still ensuring that panelists have deep familiarity with the supervisory process.

In addition, the final guidelines would expand institutions’ appellate rights by allowing appeals in certain cases where a formal enforcement action is proposed or pending. Under the final guidelines, the facts and circumstances underlying a proposed formal enforcement action would be in scope for appeals to the Office under certain circumstances, which would allow an independent review in cases where supervisory determinations may have significant consequences for an institution.

I thank the staff for their work and look forward to the Office becoming operational.

| 1 | See Federal Deposit Insurance Corporation, Guidelines for Appeals of Material Supervisory Determinations, 90 Fed. Reg. 33942 (July 18, 2025). |
Last Updated: January 22, 2026