New and independent office will help ensure fairness and consistency for responsible, innovative community banks

Goldfeder: “Acting Chairman Travis Hill has been a breath of fresh air at the FDIC”

Washington, D.C. (July 22, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, today announced its strong support for the Federal Deposit Insurance Corporation’s (FDIC) proposal to establish an independent Office of Supervisory Appeals. AFC has long advocated for modernizing the FDIC’s supervision process to ensure fairness and accuracy, particularly for providers of safe and responsible innovative products and services. The proposal would replace the Supervision Appeals Review Committee (SARC) as the final level of review for material supervisory determinations, a critical reform designed to promote fairness, transparency, and consistency in the examination process for financial institutions.

“Acting Chairman Travis Hill has been a breath of fresh air at the FDIC and we strongly support the proposal to modernize and strengthen the supervisory appeals process,” said Phil Goldfeder, CEO of the American Fintech Council. “Our members depend on a regulatory system that is clear, consistent, and accountable. This independent appeals office is a pragmatic step forward that will ensure supervisory decisions are evaluated by experienced, impartial reviewers and provide institutions with a meaningful avenue to raise legitimate concerns.”

The FDIC’s proposed structure establishes the Office of Supervisory Appeals as a standalone entity within the agency, staffed by professionals with relevant supervisory and industry expertise. The Office would report directly to the FDIC Chairperson and help ensure consistent application of supervisory standards, regardless of an institution’s business model or products.

“The FDIC’s effort to establish the Office of Supervisory Appeals shows a strong commitment to good governance and ensuring a clear supervisory structure that allows banks, including those institutions committed to responsible innovation, the ability to exercise their rights to appeal supervisory determinations without the concern of retaliation. Over the years, we’ve seen how inconsistent examination practices, especially in the context of innovative financial products, can create unnecessary barriers for institutions committed to responsible innovation,” said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC. “By instituting an independent appeals process, the FDIC is fostering a more transparent, accountable, and predictable regulatory environment in a manner that restores trust in the process and benefits regulators, institutions, and ultimately, consumers.”

AFC has been a strong supporter of regulatory modernization, including the Fair Audits and Inspections for Regulators’ (FAIR) Exams Act, which would codify many of the concepts contained in the FDIC’s proposal. In addition, AFC has consistently advocated for pragmatic and reasonable updates to modernize the examination and appeals process, including in comprehensive recommendations to the House Financial Services Committee, comments on a joint agency request for information (RFI) on bank-fintech partnerships, and further engagement with regulators.

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC’s mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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