On March 12, James Williams published “5 Takeaways From OCC's 'Appealing' Exam Challenge Revamp” in Law360. The following is an excerpt:
On Feb. 17, the Office of the Comptroller of the Currency proposed a significant overhaul of its internal appeals process that would make it easier for banks to challenge exam findings. This proposal is designed to increase the independence of the current appeals process, and is likely to improve transparency in OCC decision-making standards and ensure that banks feel more comfortable submitting appeals without fear of retaliation.
OCC Proposal
While the OCC's notice of proposed rulemaking, or NPRM, proposes several structural and procedural changes to its existing bank appeals framework, there are five high-level changes that OCC-supervised banks, their partners and their counsel will want to pay attention to.
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