The American Bankers Association (ABA) appreciates the opportunity to respond to the OCC's proposed rulemaking (Proposal) regarding its Bank Appeals Process. ABA strongly supports the Proposal and believes that an independent supervisory appeals process would serve as a crucial backstop to support and promote fair and consistent supervision. We also concur with the OCC's observation that the low number of appeals in recent years could be attributable to a perception by OCC-supervised institutions that the Bank Appeals Process is not structured to engender confidence that institutions' appeal will receive fair consideration, and is therefore not worth the resources. ABA believes that the Appeals Board's proposed use of a de novo standard of review would be a positive step forward in changing this perception. While the ABA strongly supports the Proposal, we encourage the OCC to consider the recommendations outlined in the attached letter.
Bank Appeals Process
Activity
American Bankers Association filed 1 comment on this docket between Apr 20, 2026 and Apr 20, 2026. 2 other organizations filed here. The comment window closed 99d ago.
What American Bankers Association filed (1)
Abstract
The Providing Accountability Through Transparency Act of 2023 requires that a notice of proposed rulemaking include the internet address of a summary of not more than 100 words in length of a proposed rule, in plain language, that shall be posted on the internet website www.regulations.gov. The Office of the Comptroller of the Currency (OCC) is issuing a notice of proposed rulemaking to establish revised procedures and policies for appeals of material supervisory determinations by OCC supervised entities. The proposed changes would reflect the OCC’s experience administering the bank appeals process and are intended to enhance the independence and efficiency of the appeals function. The proposed changes would include changing the role of the Ombudsman, establishing an Appeals Board to decide appeals, and clarifying a de novo standard of review. The proposal and the required summary can be found for the OCC at https://www.regulations.gov by searching for Docket ID OCC–2026–0001 and https://occ.gov/topics/laws-andregulations/ occ-regulations/proposedissuances/index-proposedissuances.html.
View on regulations.gov →Co-filers (2)
See everyone who commented →- American Bankers AssociationTHIS ORG1 filing · confidence 97%
- Axos Bank1 filing · confidence 97%
- Bank Policy Institutetrade assoc.1 filing · confidence 97%