Financial Institutions Group attorneys Pinchus D. Raice, Jeffrey Alberts, and Dustin N. Nofziger recently published an article in The Banking Law Journal entitled "The Federal Reserve Board Significantly Revises Intra-Agency Appeals Procedures." The authors summarize significant changes to the Federal Reserve Board's (Board's) intra-agency appeals procedures, which the Board updated for the first time in 25 years in March 2020, and offer an analysis of takeaways for financial institutions.
Notably, several of the Board's recent changes to the intra-agency appeals process were in response to a comment letter submitted by the authors on behalf of the New York League of Independent Bankers (NYLIB). In their article in The Banking Law Journal, the authors conclude that the Board's recent revisions to the appeals procedures "are positive for financial institutions in that they make the Board's intra-agency appeals process more useful, fair, and transparent."
The Board allows financial institutions to appeal material supervisory determinations such as CAMELS, ROCA, and consumer compliance ratings; the adequacy of loan loss reserves and/or capital; significant loan classifications; accounting interpretations; and matters requiring attention ("MRAs") and matters requiring immediate attention ("MRIAs").
The full article is available here.
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