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September 16, 2025

A Strong Supervisory Appeals Process Makes the Banking System Stronger and Protects All Americans

WASHINGTON, D.C.— Shayna Olesiuk, Director of Banking Policy at Better Markets, issued the following statement in connection with today’s filing of a comment letter to the Federal Deposit Insurance Corporation (FDIC) on proposed changes to guidelines for handling supervisory appeals.  

“It is vital to have a supervisory appeals process that is strong and fair for all banks, and does not just favor the largest Wall Street banks. We applaud the FDIC for its effort to further strengthen the supervisory appeals process, and we support the core of this proposal. However, there are two important aspects we believe should be changed.  

“First, allowing bankers, or other individuals with no bank supervisory or examination experience to decide appeals is wrong. This undermines the FDIC’s supervisory authority. Only those with direct supervisory experience should be allowed to decide appeals. Banking industry experience alone is an insufficient standard. 

“Second, establishing an entirely new office at the FDIC to handle appeals is unnecessary. The volume of appeals work does not justify the creation of an entirely new office, especially in light of significant staffing cuts this year. The agency can and should maintain its structure of having the appeals committee report directly to the FDIC Board. 

“When it comes to supervisory decisions, a robust, fair, and independent appeal process available to all banks makes the banking system stronger and benefits all Americans. We hope that the FDIC heeds these changes in their otherwise good proposal to strengthen the supervisory appeals process.”  

The Comment Letter is available here 

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