FDIC Amends Guidelines for Appeals of Material Supervisory Determinations

FDIC Financial Institution Letters

Published January 22nd, 2026

Detected March 12th, 2026

Summary

The FDIC is amending its Guidelines for Appeals of Material Supervisory Determinations by replacing the Supervision Appeals Review Committee with a new Office of Supervisory Appeals. This office will serve as the final review level for supervisory determinations and will also expand appeal rights to certain enforcement action cases.

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What changed

The Federal Deposit Insurance Corporation (FDIC) has issued amendments to its Guidelines for Appeals of Material Supervisory Determinations, establishing a new, independent Office of Supervisory Appeals. This office will replace the existing Supervision Appeals Review Committee and will function as the ultimate authority for reviewing material supervisory determinations made by FDIC divisions. Notably, the amendments also broaden the scope of appealable matters to include certain proposed or pending enforcement actions, providing institutions with expanded recourse.

Financial institutions supervised by the FDIC should be aware of these changes, particularly the new appeal process and the expanded rights concerning enforcement actions. The FDIC will issue further notification once the Office of Supervisory Appeals is operational. While no specific compliance deadline is mentioned for institutions, understanding the new appeal structure and its implications for challenging supervisory decisions and enforcement proposals is crucial for ongoing compliance and risk management.

What to do next

Review the amended FDIC Guidelines for Appeals of Material Supervisory Determinations.
Familiarize compliance and legal teams with the new Office of Supervisory Appeals and its procedures.
Monitor FDIC communications for the operational launch date of the Office of Supervisory Appeals.

Source document (simplified)

Amendments to FDIC Guidelines for Appeals of Material Supervisory Determinations

Supervisory Guidance January 22, 2026

Summary:

The FDIC is amending the agency’s Guidelines for Appeals of Material Supervisory Determinations (Guidelines). Through these amendments, the FDIC is replacing the current Supervision Appeals Review Committee with an independent, standalone office within the FDIC, known as the Office of Supervisory Appeals (Office). The Office will serve as the final level of review of material supervisory determinations made by the FDIC.

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

Highlights:

The Office will be independent of the Divisions that make supervisory determinations. An institution may appeal a material supervisory determination to the Office after the appropriate Division Director’s review of the material supervisory determination.
The Office will 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. Each panel will include at least one reviewing official with bank supervisory experience and at least one reviewing official with industry experience. Reviewing officials will be subject to confidentiality and conflict of interest requirements.
The Office will 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.
In addition, institutions’ appeal rights will be expanded to permit appeals in certain cases when an enforcement action is proposed or pending.
The FDIC will notify institutions once the Office is operational. FIL-2-2026 ## Attachment(s)

Federal Register Notice - Office of Supervisory Appeals