Treasury Speeds Up Bank Appeals to Keep Finance Fair
Published Date: 2/17/2026
Proposed Rule
Summary
The Office of the Comptroller of the Currency (OCC) is updating how banks can appeal big decisions made about them. These changes aim to make the appeals process faster and fairer for banks supervised by the OCC. If you’re involved, get your comments in by April 20, 2026, to have your say before the new rules take effect.
Analyzed Economic Effects
7 provisions identified: 6 benefits, 1 costs, 0 mixed.
More entities can file appeals
The OCC proposes to broaden who may appeal by defining “supervised entity” to include national banks, Federal savings associations, U.S. agencies or branches of foreign banks, permitted payment stablecoin issuers, and foreign payment stablecoin issuers. The rule explicitly says uninsured institutions (for example, uninsured national trust banks) are included so they may seek review of OCC material supervisory determinations.
De novo review required on appeal
The OCC proposes to define and apply a “de novo standard of review,” meaning appeals would be considered anew without deference to the original supervisory decision. The proposal says both the Deputy Comptroller (on initial appeal) and the Appeals Board (on further appeal) would apply a de novo standard.
Certain actions remain non-appealable
The proposed rule clarifies that certain matters remain not appealable, including appointments of receivers and conservators; formal enforcement-related actions (such as issuance of cease-and-desist orders or assessments under 12 U.S.C. 1818); FOIA requests or FOIA-governed submissions; disapprovals of directors or senior officers under 12 U.S.C. 1831i; and other agency decisions subject to judicial review.
Shared National Credit (SNC) appeals codified
The proposal would codify the SNC appeals process: an agent bank may appeal on behalf of participant banks, participant banks may appeal on their own if the agent bank refuses, and SNC appeals must be filed within 14 days of notification of the preliminary disposition. Appeals are to be filed with the regulator that supervises the agent bank or, when no agent is named, with the regulator that reviewed the SNC.
Ombudsman replaced by Appeals Board
The proposal would replace the current Ombudsman decision role with an Appeals Board made up of the Chief National Bank Examiner and two term appointees (term appointees would not be current OCC employees and would not be eligible for reappointment). The OCC would publish a redacted version of the Appeals Board's written decision and any redacted dissents on its website.
Deadlines and decision timelines kept
The proposed rule keeps existing timing rules: appeals generally must be filed within 60 days of receiving the disputed decision, fair-lending referrals must be appealed within 15 days, and SNC appeals must be filed within 14 days. The Deputy Comptroller and the Appeals Board would generally issue written decisions within 45 days of receiving an appeal.
Individuals can appeal some informal actions
The proposed rule allows an institution‑affiliated party (an individual directly affected by an informal enforcement action) to appeal that informal enforcement action, though it does not create a general right for individuals to appeal other OCC decisions.
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