Pryor Cashman Assists NYLIB in Submitting Comments to FDIC on Appeals Process
Pryor Cashman attorneys Pinchus D. Raice and Dustin N. Nofziger assisted the New York League of Independent Bankers (NYLIB) in submitting comments to the Federal Deposit Insurance Corporation (FDIC) on proposed amendments to the FDIC’s Guidelines for Appeals of Material Supervisory Determinations.
The FDIC’s appeals process allows financial institutions to appeal material supervisory determinations such as examination ratings and MRAs.
NYLIB’s comment letter advocates for bank-friendly changes to the appeals process, such as including bankers and outside counsel to banks on appeals panels and allowing banks to request extensions of deadlines. The comment letter also suggests that the FDIC provide banks with draft reports of examination prior to finalization to facilitate the correction of factual inaccuracies in final reports and thereby reduce the need for appeals.
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Pryor Cashman’s Financial Institutions Group provides comprehensive representation to banks and other financial institutions. Co-led by a former federal bank regulator and a former member of the U.S. Attorney’s office, we couple an insider’s perspective with decades of experience handling negotiations with bank regulators. Our team includes skilled banking litigators with experience handling intra-agency appeals, regulatory enforcement proceedings and receivership lawsuits, government criminal investigations, and internal investigations.
