Executive Summary 13 Minute Read Our Financial Services Team examines a proposed rule by the Federal Deposit Insurance Corporation (FDIC) that would On July 15, 2025, the Federal Deposit Insurance Corporation (FDIC) proposed revising its guidelines for appealing material supervisory determinations. The Proposed Rule reflects an effort to enhance the independence, clarity, and fairness of the FDIC’s internal appeals process in response to years of criticism from regulated institutions and trade groups. If adopted, the revised guidelines would strengthen procedural protections, increase transparency, and replace the FDIC’s existing Supervision Appeals Review Committee (SARC) with a standalone office within the FDIC known as the Office of Supervisory Appeals (OSA).