ICBA commended the FDIC for proposing to create an independent office within the agency to review material supervisory determinations. While the best approach is creating a separate appeals office independent of the federal banking agencies, ICBA said, the FDIC plan is a positive step toward a more transparent and independent appeals process.
ICBA encouraged the agency to expand the panel that would be reviewing appeals from three to five members and require that two have community banking experience. It also said all decisions should be publicized so bankers are aware of the process.
