The FDIC has adopted changes to its Guidelines for Appeals of “Material Supervisory Determinations” (e.g., exam ratings, determinations, loan loss reserve adequacy, significant loan classifications, etc.). The changes went into effect on July 18th and are intended to enhance the ability to appeal and bring the FDIC’s Guidelines more in line with those of other Agencies. The changes:
- Allow appeal of the level of compliance with an existing formal enforcement action, the decision to initiate an informal enforcement action (e.g., Memoranda of Understanding) or a Matter Requiring Board Attention;
- State that a formal enforcement-related action/decision does not affect a pending appeal subject to the Guidelines;
- Provide additional appeal opportunities through the Supervision Appeals Review Committee (SARC) in certain circumstances when an enforcement action isn’t pursued within 120 days; and,
- Provide for annual reports to be published on Division Directors’ decisions.
Other limited technical and conforming amendments are also included.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!