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ARTICLE · 13 MARCH 2026

OCC Proposes Overhaul Of Appeals Process

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Following on the FDIC's recent issuance of updated guidelines for appeals of material supervisory determination, the OCC is now proposing to replace the existing guidance for handling appeals...

United StatesLitigation, Mediation & Arbitration
Ronald K. Vaske
Ronald K. Vaske
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Following on the FDIC's recent issuance of updated guidelines for appeals of material supervisory determination, the OCC is now proposing to replace the existing guidance for handling appeals of material supervisory determinations at institutions under its jurisdiction and to create a board to decide bank appeals. The deadline for comments on the proposal is April 20, 2026.

Under the proposed process, an institution could appeal a material supervisory determination to the Deputy Comptroller of the Division that decided the issue being appealed or the institution could appeal directly to the new Appeals Board. An institution disagreeing with a determination by the Deputy Comptroller could also seek review by the new Appeals Board.

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