Office of the 

Ombudsman

REPORT ON ACTIVITIES

2019 & 2020
ABOUT THE COVER PHOTO

THE GREAT SEAL OF THE UNITED STATES

LOBBY OF THE FDIC HEADQUARTERS BUILDING

FEDERAL DEPOSIT INSURANCE CORPORATION

550 17th Street, N.W., Washington, D.C.

Since its formal dedication on June 16, 1963, 

the Great Seal of the United States has been 

prominently displayed for any visitor to the 

Federal Deposit Insurance Corporation building. 

Affixed to the lobby wall opposite the bronze doors, 

the Corporation’s Great Seal is a handsome example 

of a specialized form of art. Weighing 4,000 pounds 

and standing 12 feet tall, this Great Seal is believed 

to be the largest Great Seal ever cast. 

Artisans at G.L. Giannetti Studios were commissioned 

to create this artwork as they had been revered 

for handling such assignments for many years in 

the local Capital Region area. The head of the firm, 

Gregory L. “George” Giannetti, a master craftsman 

of ornamental and architectural sculpture, along 

with his son, Robert Giannetti, worked for over six 

months to complete the sculpture, beginning with 

the making of a three-foot model. The plaster mold 

was so large that Robert had to disassemble it and 

drive the pieces in the back of his pick-up truck in 

order for the mold to be cast in bronze by Bedi and 

Rossi, an art foundry in Brooklyn, New York. 

The symbolism of the Great Seal consists of a large 

bald eagle, holding an olive branch in his right talon, 

and arrows in his left talon. He faces the right, and 

bears on his breast the shield of the United States. 

He holds in his beak a streamer on which is the 

national motto “E. Pluribus Unum” (Out of Many, 

One). Above his head is the Constellation, including 

13 stars. The number 13, representing the 13 original 

states, repeats in the arrows, the olive branch, leaves, 

berries, and the stripes.

FDIC History

A special thank you to the FDIC Library team including Richard Huffine, Alicia Amiel, Renee Mccullough, and Stan Smith, as well as to the 

FDIC Historian, Lee Davison, for providing extensive historical research and photographs in support of this publication. 
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 1

Table of Contents

Message from the Director.............................................4

Our History....................................................................5

Our Stakeholders...........................................................6

Our Standards of Practices............................................7

Our Core Values.............................................................8

INTRODUCTION

Listening Sessions and Webinar.................................10

Listening Sessions’ Key Findings................................11

Post-Examination Survey............................................12

Serving as a Pandemic Resource.................................13

Goals for 2021 and Beyond.........................................14

MAJOR ACTIVITIES DURING 2019 & 2020

Overview of National Network...................................16

Senior Management...................................................17

Regional Ombudsmen................................................18

Stakeholders in the Regions.......................................19

Senior Ombudsman Specialists..................................20

ORGANIZATIONAL STRUCTURE

Overview of Individual Industry Cases......................22

A. Requests for Information............................23

B. Problem Solving Cases...........................24-25

C-E. Remaining Categories of Industry Cases

C. FDICconnect Issues..............................26

D.Whistleblower-Bank practices..............26

E. Other Recommendations & Feedback...26

INDIVIDUAL INDUSTRY CASES

SECTION A

SECTION B

SECTION C

SECTION D
2 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Table of Contents

SECTION E

SECTION F

SECTION G

SECTION H

General Public Inquiries.............................................48 

Determining Optimal Course of Action......................49

FDIC Matters Resolved Internally: 2019......................50

FDIC Matters Resolved Internally: 2020......................51

Customer Satisfaction Survey.....................................52

Open-Ended Survey Responses.................................53

PUBLIC INQUIRIES AND REFERRALS

General Contact Information.....................................55

Senior Management...................................................56

Regional Ombudsmen................................................57

CONTACT FDIC’S OFFICE OF THE OMBUDSMAN

FEDERAL OMBUDSMEN DIRECTORY

Overview of Industry Outreach Visit..........................28

Outreach Feedback Items Specific to 2020.............29

Patterns of Frequent Feedback Items.......................30

A. Feedback Items: Examination Matters...............31

A1. Risk Management Supervision (RMS).........33

A2. Examination Process..................................34

A3. Depositor & Consumer Protection (DCP)....35

A3. Non-Specific DCP Feedback Items..............36

B. Feedback Items: Other Regulatory Matters.......37

B1-2. Bank Applications and Credit Loss.........39

B3-5. Bank Secrecy and FDIC Operations.........40

B6-8. Appeals Process and Regulations...........41

B9-11. CRA and Interest Rate Restrictions........42

C. Feedback Items: Banking Environment..........44

C1-3. Coronavirus Impact and Relief..............45

C4-9. Agricultural Economy and Other...............46

INDUSTRY OUTREACH VISITS

................58-60
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 3

Introduction

SECTION A
4 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Message from the Director

I

n 2019, the FDIC’s Office 

of the Ombudsman 

(the Office) released 

the first public report on 

its activities in almost a 

decade. The report covered 

a range of information and 

metrics on our case work 

for 2018, including, areas of 

assistance provided to 

the banking industry, 

recommendations provided 

to the examination 

Divisions, and anticipated 

areas of focus for the Office in the upcoming year. 

The report also included information on our Regional 

Ombudsmen, and their contact information. 

On behalf of Chairman Jelena McWilliams and the 

entire FDIC Board of Directors, I am pleased to present 

our latest Report, which highlights activities of the 

Office for calendar years 2019 and 2020. Based on 

feedback we received for the previous report, we 

have endeavored to provide more substantive detail 

on specific assistance provided to the industry, while 

still including important benchmarks regarding 

outreach activities. 

This report chronicles two busy years for the Office, 

including participation in a number of meetings 

and calls with bankers around the country on 

issues pertaining to disagreements with specific 

bank examination findings, concerns regarding the 

professionalism or courtesy of FDIC staff, and the 

identification of relevant information and points of 

contact for pending applications. One of the major 

initiatives undertaken by the Office in 2019 was the 

assumption of oversight and responsibility for the 

agency’s Post-Examination Survey process. This 

action has afforded bankers with an added degree 

of confidence in providing more candid commentary 

and recommendations regarding the examination 

processes. As part of the Chairman’s Trust Through 

Transparency initiative, the Office also hosted a series of 

Listening Sessions (both in-person and virtual), to solicit 

comments and observations from the industry 

on the FDIC’s current appeals processes. 

As this report is being published, a significant number 

of public and private enterprises around the country, 

including banks and savings associations, are operating 

pursuant to certain restrictions on their business 

activities. The COVID-19 Pandemic (the Pandemic) 

has materially impacted virtually all facets of the 

personal and professional lives of each American 

citizen, including our FDIC family. The Pandemic has 

also curtailed on-site outreach activities of this Office, 

which have proven in the past to be integral in building 

industry trust and confidence for contacting and 

discussing sensitive matters with Ombudsman staff. 

However, through the use of technology and virtual 

platforms, we have continued with our mission of 

assisting the industry in resolving disagreements with 

the agency, as well as providing responses to regulatory 

related questions.

Your feedback on the report is welcome, and you may 

contact me directly via mlowe@fdic.gov, or may use 

other communication channels provided on the final 

pages of this report.

Thank you, and I hope you enjoy the report!

INTRODUCTION

M. ANTHONY LOWE

Director, Office of the Ombudsman, FDIC

OFFICE OF THE OMBUDSMAN GENERAL CONTACT INFO: (877) 275-3342 ombudsman@fdic.gov
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 5

Our History

The Riegle Community Development and Regulatory 

Improvement Act of 1994 (Riegle Act) became law on 

September 29, 1994. Title III, Section 309(d) of the 

Riegle Act required all Federal banking agencies to 

establish an Ombudsman to:

• act as a liaison between the agency and any 

affected person with respect to any problem 

such party may have in dealing with the agency 

resulting from the regulatory activities of the 

agency; and 

• ensure that safeguards exist to encourage 

complainants to come forward and to 

preserve confidentiality.

I

n 1993, the FDIC announced that an Ombudsman 

would be located in each FDIC Division of 

Liquidation Service Center to “facilitate action on 

complaints and questions from borrowers, lenders, 

and public officials” in connection with the FDIC’s 

liquidation activities1. At that time, oversight and policy 

direction for these regional and field office Ombudsmen 

was provided by the Washington Office of Congressional 

Affairs and Public Relations, which was part of the 

former Division of Depositor and Asset Services (DAS). 

In advance of the Riegle Act becoming law, the FDIC 

Board of Directors, by Resolution (057628) adopted 

August 30, 1994, formally established the Office of the 

Ombudsman to replace the former FDIC Ombudsman 

function and expanded the scope of its activities to 

include the Corporation’s resolution, receivership, and 

asset disposition activities.

THE RIEGLE ACT OF 1994

1

The Resolution Trust Corporation (RTC) had a similar function that handled problems concerning all RTC activities. In this capacity, the 

Resolution Trust Corporation Completion Act required that a client responsiveness unit responsible to the RTC’s ombudsman exist at every 

RTC regional office.

INTRODUCTION

Photo courtesy of iStock / Getty Images Plus
6 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Our Stakeholders

The Office of the Ombudsman’s stakeholders 

(individuals, groups, or organizations) are 

those who are impacted by the actions of 

the FDIC or have an interest in the FDIC successfully 

fulfilling its mission. External stakeholders are any 

person, group or organization having an issue with 

the FDIC resulting from a regulatory, resolution, 

receivership, or asset disposition activity, or with 

anyone at the FDIC involved in carrying out such 

activities. Internal stakeholders primarily consist of 

Office of the Ombudsman staff, other FDIC divisions 

and offices, and the FDIC Chairman. 

The Office of the Ombudsman strives to promote 

fairness by facilitating communication, increasing 

transparency, and raising awareness of issues and 

concerns, all while preserving confidentiality. We 

accomplish this through the activities listed below. 

FAIRNESS FOR ALL STAKEHOLDERS

• serving as a resource for information concerning 

FDIC processes prior to conflicts entering a 

formal channel, including appeals of material 

supervisory determinations or deposit 

insurance assessments; 

• advocating for fair and impartial processes at 

the FDIC;

• facilitating efficient and effective

communication between the FDIC and all of 

its stakeholders; 

• providing an FDIC perspective for external 

stakeholders, and conversely, providing the 

viewpoint of bankers to internal stakeholders 

and decision makers;

• reporting to the FDIC Chairman’s Office on 

feedback from stakeholders, particularly in 

regards to systemic or actionable issues;

• interacting with other FDIC divisions and offices 

to address issues raised by stakeholders and 

encouraging improved policies or practices;

• serving as the FDIC’s Freedom of Information Act 

(FOIA) Public Liaison to resolve issues; and

• participating in bank closings with the FDIC’s 

Division of Resolutions and Receiverships (DRR) 

by serving as public confidence liaisons for 

those affected by failed bank activities, and 

serving as an on-site media contact in a 

back-up role to the Office of Communications.

INTRODUCTION

WE PROMOTE FAIRNESS BY: 

Photo courtesy of iStock / Getty Images Plus

THE OFFICE OF THE OMBUDSMAN SERVES BOTH 

EXTERNAL AND INTERNAL STAKEHOLDERS
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 7

Our Standards of Practices

The FDIC is committed to fair regulatory 

practices and actions, supports the right of 

the regulated banking community to raise 

concerns without the fear of retaliation, and will 

investigate any allegations of retaliation and ensure 

appropriate corrective action is taken. Financial 

institutions regulated by the FDIC may direct 

comments regarding possible retaliation to their 

appropriate Regional Director, or direct comments 

confidentially to the Office of the Ombudsman.

FREEDOM FROM ANY RETALIATION 

• impose, interfere with, or modify any statutes, 

regulations, or laws, including any related 

policies, practices, or procedures followed or 

enforced by the FDIC;

• make decisions or legal determinations, or 

serve as a formal office of legal notice; 

• make binding decisions, or mandate policies 

for the FDIC;

• overturn any decisions of existing dispute 

resolution or appellate bodies;

• provide any financial, legal, or 

investment advice;

• serve in any role that compromises 

the impartiality of the Office; or

• intervene or participate in any 

formal processes.

INTRODUCTION

THE OFFICE OF THE OMBUDSMAN CANNOT:

FDIC supports the 

right of the regulated 

banking community to 

raise concerns without 

the fear of retaliation. 

While the Office of the Ombudsman will investigate 

any allegation of retaliation, a complaint to the Office 

will not terminate or delay agency regulatory actions 

or administrative proceedings as part of the FDIC’s 

ongoing responsibility to enforce Federal 

laws and regulations. 

For a financial institution or institution affiliated 

party subject to a regulatory action by the FDIC, any 

obligation with respect to an enforcement or corrective 

action is not affected by the filing of a complaint 

regarding retaliation with this Office.

Photo courtesy of iStock / Getty Images Plus
8 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

The Office of the Ombudsman is independent of the 

FDIC’s supervisory process, including being free from 

control, limitation, or retaliation. The Office reports 

directly to the FDIC Chairman’s Office.

As an advocate for fair processes, the Office 

reviews facts, considers all sides, and promotes 

communication among concerned parties. 

The Office holds all communications with those 

seeking assistance in strict confidence and takes all 

reasonable steps to safeguard confidentiality. The 

Office does not share the identity of the stakeholders 

who contact us with others inside or outside the 

corporation, unless confidentiality is expressly waived 

by the individual or where there exists any of the 

following factors:

INDEPENDENCE

NEUTRALITY AND IMPARTIALITY

CONFIDENTIALITY

The core values and standards of practice of the 

FDIC’s Office of the Ombudsman align with all 

of the 2004 Standards for the Establishment 

and Operation of Ombudsman Offices of both the 

American Bar Association, as well as the International 

Ombudsman Association. The following core values 

and standards of practice enable the FDIC’s Office of the 

Ombudsman to function effectively:

• imminent risk of serious harm to persons 

or property;

• allegations of fraud, waste, or abuse; or

• judicial process (e.g., subpoena, 

deposition, testimony).

Our Core Values

INTRODUCTION

STANDARDS OF PRACTICE

LEARN MORE 

Explore further information about the 2004 Standards for the Establishment and 

Operation of Ombudsman Offices of the International Ombudsman Association as 

well as the American Bar Association. Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 9

Major Activities During 2019 & 2020

SECTION B
10 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Listening Sessions and Webinar

The principal areas of discussion at the events 

included the following:

• potential barriers to disputing examination 

findings or filing an appeal of a material 

supervisory determination;

• opportunities to improve the composition and 

functions of the Supervision Appeals Review 

Committee (SARC);

• recommendations relative to timeframes for 

pursuing formal reviews at the Division Director 

and SARC levels;

• suggestions on the role of the Ombudsman in 

resolving disagreements between banks and 

examination personnel;

• opportunities for FDIC to advance its Trust 

through Transparency initiative – build trust 

and confidence with financial institutions 

through openness and accountability; and

• other observations, recommendations, or 

concerns regarding the FDIC’s processes for 

resolving disagreements.

2

Section 309(a) of the Riegle Community Development and Regulatory Improvement Act of 1994 required the Federal Deposit Insurance 

Corporation (FDIC), as well as the other Federal banking agencies and the National Credit Union Administration Board, to establish an 

independent intra-agency appellate process to review material supervisory determinations. The statute requires the FDIC to ensure that 

appeals of material supervisory determinations by insured depository institutions are heard and decided expeditiously, and that appropriate 

safeguards exist for protecting appellants from retaliation by agency examiners.

AREAS OF DISCUSSION:

MAJOR ACTIVITIES DURING 2019 & 2020

Consistent with the FDIC’s Trust through 

Transparency initiative, this Office completed 

a nationwide series of eight in-person Listening 

Sessions, and one Webinar, to solicit comments, 

observations, and recommendations from the 

FDIC-supervised institutions and other interested 

parties on the FDIC’s existing Appeals2 processes. 

Participants included approximately 100 industry 

representatives for the in-person Listening Sessions, 

and 135 for the Webinar.

Representatives from the FDIC’s Legal Division and 

the Office of Communications assisted in planning 

and hosting each of the events. The Listening 

Sessions and Webinar also invited recommendations 

from participants for enhancing publicly available 

information on agency operations.

To encourage candid discussions and input at each 

of the events, the participants were advised that the 

sessions would not be recorded, there would be no 

FDIC attendees from the examination Divisions, and 

their comments would be summarized without specific 

attribution to a particular person or bank. 

Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 11

KEY FINDING: FEAR OF RETALIATION

Listening Sessions’ Key Findings

Participants also observed that SARC decisions are not 

sufficiently detailed, on the FDIC’s public website, in a 

manner that is beneficial for other banks to gain insight 

or “lessons learned” from previously resolved disputes. 

The participants’ comments, observations, and 

recommendations on the areas of focus from the events 

were aggregated and shared with senior executives at 

the FDIC, including the Chairman’s office.

When polled, a large portion of participants 

at the in-person Listening Sessions 

commented that a fear of retaliation often 

inhibits decisions by bankers against filing appeals of 

material supervisory determinations. 

MAJOR ACTIVITIES DURING 2019 & 2020

• reduce or eliminate consecutive Examiner-InCharge assignments; 

• provide additional transparency to the 

industry regarding retaliation; 

• facilitate an out-of-territory team of 

examiners to conduct the examination 

immediately subsequent to the filing of an 

appeal; and 

• augment membership of the SARC with an 

independent party. 

RECOMMENDATIONS

OTHER FINDINGS

Participants offered the following recommendations 

to address retaliation concerns: 

EVENT MATERIALS

Materials utilized during the 

Listening Session events are 

available digitally for download.

3

On January 19, 2021, the FDIC’s Board of Directors adopted revised Guidelines for Appeals of Material Supervisory Determinations. The 

revised guidelines are intended to enhance the independence of appeals decisions and to clarify the procedures and timeframes that apply to 

appeals when the FDIC is taking a formal enforcement action. The revised guidelines generally replace the existing Supervision Appeals Review 

Committee (SARC) with an independent, standalone office within the FDIC, known as the Office of Supervisory Appeals. The revised guidelines 

will take effect when that new office is fully operational; current guidelines will remain in effect until that time. FIL-04-2021

On August 21, 2020, The Board of Directors of the 

Federal Deposit Insurance Corporation (FDIC) 

approved a proposal to amend its Guidelines for 

Appeals of Material Supervisory Determinations. 

Changes to the supervisory appeals process were 

proposed, in part, based on the above Listening 

Sessions the FDIC’s Ombudsman held with 

bankers and other interested parties in the fall of 

2019, and the Office of the Ombudsman worked 

with the Legal Division and others at the FDIC on 

the proposal.

The most significant change in the proposal would 

be to replace the current Supervision Appeals 

Review Committee (SARC) with an independent, 

standalone Office of Supervisory Appeals (Office) 

within the FDIC.

The Office would have final authority to resolve 

appeals and would be independent within the 

FDIC organizational structure. The Office would 

be staffed by individuals with bank supervisory or 

examination experience. To further promote its 

independence, the FDIC would recruit externally 

to staff the Office. An institution unable to resolve 

a disagreement regarding a material supervisory 

determination with the examiner or the 

appropriate Regional Office or Division Director 

would be able to appeal that determination to the 

Office. The FDIC believes that the creation of the 

proposed Office would promote independence 

and help alleviate perceived conflicts of interest, 

among other important goals.

AMENDING THE GUIDELINES FOR APPEALS 

OF MATERIAL SUPERVISORY DETERMINATIONS3

KEY FINDING: AMENDMENT PROPOSAL
12 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

SOLICITING SURVEY RESPONSES

Post-Examination Survey

MAJOR ACTIVITIES DURING 2019 & 2020

On October 1, 2019, the FDIC’s Office of the 

Ombudsman assumed responsibility for 

soliciting responses for Safety & Soundness, 

Compliance, and Community Reinvestment Act 

Post-Examination Surveys. 

The Post-Examination Survey feedback is used to 

improve the quality and efficiency of examination 

procedures, maintain examiner standards of 

professionalism, and ensure that examinations remain 

a beneficial tool for achieving safety and soundness 

standards and regulatory compliance. 

SUMMARY AND SURVEY QUESTIONS

Explore further information about the Post-Examination Survey including 

downloading4 the relevant Financial Institution Letters (FIL), a copy of the survey 

questions related to each survey, and summary and background of any changes 

to the Survey process. 

LEARN MORE ABOUT THE POST-EXAMINATION SURVEY

4

The full hyperlink address is https://www.fdic.gov/news/financial-institution-letters/2019/fil19050.html

In addition to assuming responsibility for soliciting 

responses, the Office of the Ombudsman: 

sends banks notifications that the PostExamination Survey will accompany the 

Report of Examination, 

provides reminders to encourage participation 

in the Post-Examination Survey, and

serves as the point of contact for the PostExamination Survey and any follow-up requests.

The changes to the Post-Examination Survey process 

were made in order to enhance confidentiality and 

empower bankers to provide candid responses to 

Post-Examination Survey questions.

3

2

1

Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 13

Serving as a Pandemic Resource

This Office’s pivot and responsiveness to the 

needs of internal and external stakeholders, 

as well as our own staff, was of paramount 

importance in 2020. Working under mandatory 

telework constraints and safeguards, we successfully 

responded to an increased volume of Pandemicrelated inquiries and requests. Starting on March 16, 

2020, all outreach with the industry was conducted 

remotely by phone and video calls, as well as through 

virtual attendance at Trade Association events and 

conferences. While the Office’s outreach program 

converted to an entirely virtual process, it remained 

robust and effective in facilitating assistance to 

stakeholders, while gathering critical feedback for FDIC 

leadership. The Office provided timely information 

to the public, furnished the agency with feedback on 

regulatory communications and guidance, and served 

as a valuable contact point for banks dealing with a 

dramatically changed operating environment.

The Pandemic increased the urgency for the Office to 

be responsive to our stakeholders. During 2020, we 

experienced a 57% increase in calls from the general 

public as they dealt with issues such as stimulus 

checks, unemployment benefits, and related scams. 

The volume of Pandemic-related requests, including 

regulatory relief and exam scheduling, increased

the overall industry cases total by 82%. The Office

supported bankers to rapidly implement Pandemic

response programs that significantly impacted

customer access. Additionally, Industry Outreach

conducted on a regular basis by the Regional

Ombudsmen included 232 direct Pandemic-related

comments, with Pandemic-themed comments running

through a majority of other feedback topics. It was an

unusual year in many respects and the Office proudly

played its part in the FDIC remaining a source of

strength in a difficult and challenging time.

MAJOR ACTIVITIES DURING 2019 & 2020

232 NUMBER OF DIRECT PANDEMIC-RELATED 

OUTREACH COMMENTS DURING 2020

57% PERCENTAGE INCREASE OF CALLS 

FROM THE PUBLIC

82% PERCENTAGE INCREASE OF INDUSTRY CASESPhoto courtesy of iStock / Getty Images Plus
14 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Continue efforts to broaden industry awareness of 

the Office and its activities through direct contacts 

with financial institutions, including Minority 

Depository Institutions and Affinity Groups, De 

Novo banks, industry trade associations, and state 

banking authorities; also, obtain feedback on FDIC 

supervisory programs and processes, and identify 

options for resolving complaints or disagreements 

between external stakeholders and the FDIC. 

Develop and implement measures for closely

monitoring response rates for the FDIC Post-Examination 

Survey, and continue to ensure feedback,messages and 

concerns of the industry, in relation to examination 

activities, are appropriately conveyed to the driver 

risk management and consumer protection divisions.

Consistent with appropriate protections for 

anonymous feedback, produce an annual 

report from the Office of the Ombudsman 

providing transparency regarding industry 

comments, observations, and feedback 

regarding FDIC operations.

ANNUAL REPORT PUBLICATIONS

BROADEN INDUSTRY AWARENESS

OUTREACH

Goals for 2021 and Beyond

MAJOR ACTIVITIES DURING 2019 & 2020

Continue to provide timely and useful 

information on relevant topics of interest 

at each meeting, as requested.

PROVIDE RELEVANT INFORMATION

ADVISORY COMMITTEE ON COMMUNITY BANKING

MEASURE SURVEY RESPONSES

POST-EXAMINATION SURVEY RESULTS

PRODUCE AN ANNUAL REPORT

Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 15

Organizational Structure

SECTION C
16 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

HEADQUARTERS: VIRGINIA SQUARE AND BUILDING 550

Overview of National Network

The Office of the Ombudsman is headquartered 

in Washington, DC, with one Regional 

Ombudsman assigned to each of the six 

FDIC Regional Offices. The majority of the Regional 

Ombudsmen have been employed by FDIC for an 

average 30 years, having previously served in roles 

such as Bank Examiners, Case Managers, and Assistant 

Regional Directors, or have held other managerial 

positions within the Corporation. This experience 

has resulted in the Regional Ombudsmen having 

a strong understanding of the FDIC’s procedures, 

operations, and mandates. Additionally, most Regional 

Ombudsmen have graduated from leadership programs 

sponsored by Graduate School USA and/or are certified 

as a Certified Organizational Ombudsman Practitioner 

(CO-OP®) by the International Ombudsman Association. 

KANSAS CITY REGION

FDIC HEADQUARTERS AND REGIONS:

SAN FRANCISCO REGION CHICAGO REGION NEW YORK REGION

DALLAS REGION ATLANTA REGION

ORGANIZATIONAL STRUCTURE
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 17

Senior Management

ASSOCIATE OMBUDSMAN AMY BROWN

The Director of the Office of the Ombudsman 

is an Officer of the Corporation, and reports 

directly to the Chairman’s Office. Director M. 

Anthony Lowe fulfills the Ombudsman role for FDIC, 

and is responsible for oversight of the agency efforts 

to resolve problems and complaints against the 

agency in a fair, impartial, and timely manner. 

Director Lowe also serves as the FOIA Public Liaison 

for FDIC, and responds to concerns presented by 

FOIA requesters relative to the service received from 

the FDIC FOIA Group. 

DIRECTOR M. ANTHONY LOWE

Director Lowe is the FDIC’s FOIA Public Liaison and 

serves as a supervisory official to whom a FOIA 

requester can raise questions or concerns about the 

service received from the FDIC’s FOIA/Privacy Act (PA) 

Group. While the FOIA/PA Group processes requests 

seeking FDIC agency records, the FOIA Public Liaison 

assists stakeholders by explaining processes or 

answering questions. Director Lowe has designated 

the Senior Ombudsman Specialists to serve as subject 

matter experts for: 

• discussing the role of the FOIA Public Liaison;

• answering questions or reviewing concerns 

about the FOIA process; and

• reducing delays, increasing transparency, 

assisting stakeholders in determining the 

status of requests, and assisting resolution of 

disputes among stakeholders. 

Reporting directly to Director Lowe is Associate 

Ombudsman Amy Brown. In this capacity, Associate 

Ombudsman Brown directs the supervision of the 

Regional Ombudsmen and Senior Ombudsman 

Specialists; she also manages outreach programs and 

corporate reporting and helps to develop solutions to 

problems presented to the Office.

INTERACTION WITH FDIC INTERNAL OMBUDSMAN

On occasion, when current or former FDIC employees contact the Office of the Ombudsman regarding work-related matters that do not involve 

bank supervisory policy, they are referred to the FDIC’s Internal Ombudsman. The Internal Ombudsman serves as a confidential, neutral, and 

independent resource providing informal assistance to all employees to address work-related issues and concerns.

FOIA PUBLIC LIAISON

ORGANIZATIONAL STRUCTURE

Photo courtesy of iStock / Getty Images Plus
18 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Regional Ombudsmen

Regional Ombudsmen are alternative, intermediary 

contacts between the banking industry and the 

FDIC within their respective regions. They serve 

as sounding boards for questions, concerns, 

or complaints regarding the FDIC’s operations, 

procedures, and communications. The Regional 

Ombudsmen establish a “case”, without identifiers, 

for each of these issues and rely on their judgment, 

experience, and resource network to provide 

stakeholders with answers to questions and options 

for consideration. Ombudsman services, such as 

shuttle diplomacy (facilitating communication with 

the appropriate FDIC office) or informal dispute 

resolution services, are offered and implemented, 

as warranted. As appropriate, they may also 

confidentially direct issues to the responsible 

parties within the FDIC in order to provide industry 

perspective on procedures or practices that may 

warrant modification.

ORGANIZATIONAL STRUCTURE

Regional Ombudsmen are experienced 

professionals who possess a strong 

understanding of the FDIC’s procedures, 

operations, and mandates, particularly in regard 

to examination and application programs. 

ALTERNATIVE RESOURCE

ROLES AND RESPONSIBILITIES

SERVE AS AN ALTERNATIVE RESOURCE FOR INDUSTRY INQUIRIES AND CONCERNS

6 NUMBER OF FDIC REGIONAL OMBUDSMEN

Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 19

Regional Ombudsmen are also tasked with 

developing and maintaining relationships with 

FDIC Regional and Field Office management and 

staff. The Regional Ombudsmen periodically meet 

with FDIC employees through presentations at staff 

meetings or other interactions. These opportunities 

enable the Regional Ombudsmen to discuss the 

confidential manner in which the Office approaches 

its work and how it can be of assistance to both FDIC 

staff and the banking industry. On an ongoing basis, 

the Regional Ombudsmen hold meetings with FDIC 

management and subject matter experts to enable 

the Regional Ombudsmen to maintain a working 

knowledge of areas of regulatory focus, as well as 

provide feedback and constructive input to the FDIC 

to improve internal operations. 

EXTERNAL STAKEHOLDERS

INTERNAL STAKEHOLDERS

As an independent resource, Regional Ombudsmen 

work throughout their regions conducting outreach 

with external stakeholders, and routinely meet 

with executives of FDIC-supervised banks, state 

trade associations, and state banking authorities. 

This outreach can take the form of an individual 

visit, a presentation at an event, networking at a 

banking conference or convention, or other similar 

activities. This robust outreach program is designed 

to ensure that external stakeholders are aware of 

the services provided by, and resources available 

from, this Office and to build familiarity with the 

Regional Ombudsman. One goal is to build trust and 

a professional rapport so that, if the need arises, an 

individual or organization has a degree of comfort 

contacting the Regional Ombudsman for assistance. 

Another goal of this outreach is to provide a unique 

feedback channel for the FDIC on industry issues. 

CONNECT WITH STAKEHOLDERS

BUILD TRUST AND DEVELOP RELATIONSHIPS BY CONNECTING WITH STAKEHOLDERS

Stakeholders in the Regions

ORGANIZATIONAL STRUCTURE

Regional Ombudsmen are focused on unfairness to 

financial institutions and, in particular, the possible 

cause and potential remedies.

The Regional Ombudsmen also serve 

as a resource for FDIC employees 

who believe a supervisory procedure, 

policy, action, or misapplication 

thereof, is unfairly impacting a 

financial institution. 

Photo courtesy of iStock / Getty Images Plus
20 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Senior Ombudsman Specialists

The Senior Ombudsman Specialists have 

considerable experience with the FDIC, working 

within risk management, compliance, and 

receivership disciplines. 

ORGANIZATIONAL STRUCTURE

ROLES AND RESPONSIBILITIES MAINTAINING PUBLIC CONFIDENCE

Senior Ombudsman Specialists work to support the 

FDIC’s mission of maintaining public confidence in 

the nation’s financial system, insuring deposits, and 

managing receiverships by:

• serving as lead public confidence liaisons for 

those affected by failed bank activities; 

• providing assurance to depositors regarding 

the safety of their insured deposits;

• communicating critical information and 

timelines related to the failure;

• anticipating sensitive or significant matters 

and discussing potential options for addressing 

customer needs before they become problems;

• providing problem-solving support for external 

and internal stakeholders, where necessary;

• ensuring lines of communication remain open 

among all parties affected by a closing; and

• serving in a back-up role to the FDIC Office of 

Communications as an on-site media resource 

during bank closings. 

BANK CLOSING REPRESENTATIVES

• responding to public inquiries received via 

phone, email, and the Internet; 

• assisting stakeholders in navigating 

organizational roles and identifying appropriate 

processes and contacts by listening and making 

referrals, as needed; 

• responding to complaints against the FDIC 

by reviewing processes for fair implementation 

of processes in complaint scenarios; and

• providing feedback regarding any observations 

or potential options to improve processes; and 

• maintaining this Office’s system of record notices 

and provide reporting data from that system.

CONTACT FOR PUBLIC INQUIRIES

The primary responsibilities of the Senior Ombudsman 

Specialists are the generation and oversight of Office 

reporting. Their roles also include serving as Contacts 

for Public Inquiries and Bank Closing Representatives.

RMS = Risk Management Supervision

DCP = Division of Depositor and Consumer Protection

DRR = Division of Resolutions and Receiverships

Photo courtesy of iStock / Getty Images Plus
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 21

Individual Industry Cases

SECTION D
22 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

227

2019 2020 2019 & 2020 CATEGORIES OF INDIVIDUAL INDUSTRY CASES

A REQUESTS FOR INFORMATION

D WHISTLEBLOWER-BANK PRACTICES 48

B PROBLEM SOLVING

C

136

65

97

(49%)

130

(36%)

47

(24%)

89

(25%)

25

(13%)

40

(11%)

21

(11%)

27

(8%)

TOTAL INDIVIDUAL INDUSTRY CASES BY YEAR 197 358 555

FDICCONNECT ISSUES

E OTHER RECOMMENDATIONS & FEEDBACK 7

(3%)

72

(20%)

A

B

C

D

E

2020

Overview of Individual Industry Cases

INDIVIDUAL INDUSTRY CASES

I

n 2019 and 2020, Regional Ombudsmen received 

individual industry cases totaling 197 and 358, 

respectively. These cases represented questions, 

concerns, complaints, and requests for assistance from 

particular banks and state banking trade associations 

regarding the FDIC’s operations, procedures, or 

communications. The increase in cases experienced in 2020 

was due in large part to the impact of the Pandemic, which 

impacted the banking industry on several fronts. Pandemicrelated cases were present in most categories. 

Another driver behind the increased number of cases in 2020 

was the October 1, 2019, transfer of administration of the Post 

Examination Survey (PES) to the Office of the Ombudsman. 

The PES provides each financial institution that undergoes 

an RMS or DCP examination the opportunity to discuss the 

examination with the Associate Ombudsman. The first 

full year of PES oversight led to an increase in cases that 

emanated from these discussions. 

79

8%

11%

25%

36%

20%
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 23

A. Requests for Information

INDIVIDUAL INDUSTRY CASES

227

2019 2020 2019 & 2020 CATEGORIES OF REQUESTS FOR INFORMATION

A REQUESTS FOR INFORMATION 97

(49%)

130

(36%)

TOTAL INDIVIDUAL INDUSTRY CASES BY YEAR 197 358 555

126

89

68

(70%)

58

(45%)

24

(25%)

65

(50%) 2

1

3

REGULATORY MATTERS

OTHER FDIC MATTERS

OTHER REQUESTS

Requests for information on regulatory 

matters dealt with questions concerning: 

• Regulations, 

• Reporting requirements, 

• Deposit insurance coverage, and 

• Other supervisory topics. 

The most frequent topics included:

• Community Reinvestment Act, 

• Appraisal regulations, 

• National interest rate caps, 

• Home Mortgage Disclosure Act,

• Call Report filing guidance, 

• Hemp-related issues, and 

• COVID-19 Office Closure Notices (2020). 

1 REGULATORY MATTERS

Regional Ombudsmen responses to these inquiries 

consisted of researching the specific issue to provide 

answers to the contacts, directing them to the 

appropriate written guidance, or referring them to 

their primary point-of-contact (i.e., Case Manager, 

Review Examiner) or a regional Subject Matter Expert. 

This group includes requests for information such 

as FDIC Executive Officer presentations, FDIC 

Signage and publications, FDIC primary contact 

information, and application-related inquiries. It also 

captures miscellaneous requests for assistance and 

contact information from bank employees, industry 

trade associations, and state banking authorities. 

Responses from the Regional Ombudsmen included 

research and referrals to the appropriate parties 

within the FDIC for specific assistance.

This group is primarily composed of bankers 

trying to connect with appropriate contacts 

at other agencies. These agencies include 

state banking authorities, the Small Business 

Administration, and other Federal regulators. 

Regional Ombudsmen responded by holding 

clarifying discussions and providing appropriate 

referrals to outside parties. 

2 OTHER FDIC MATTERS

3 OTHER REQUESTS

5

(5%)

7

(5%) 12
24 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

B. Problem Solving

INDIVIDUAL INDUSTRY CASES

2019 2020 2019 & 2020 CATEGORIES OF PROBLEM SOLVING

B PROBLEM SOLVING

TOTAL INDIVIDUAL INDUSTRY CASES BY YEAR 197 358 555

63

29

17

(36%)

46

(52%)

12

(13%)

13

(28%)

31

(35%) 44

During 2019, a key portion of the individual 

industry cases received by the Regional 

Ombudsmen pertained to requests for Problem 

Solving and the number of these cases almost doubled 

in 2020. These Problem Solving cases reflect the 

heartbeat of the Office of the Ombudsman’s mission 

and core values in serving stakeholders. The Office 

saw a notable increase in Industry Cases related to 

Regulatory Findings/Accuracy Concerns and Other 

Issues. Cases related to Staff Responsiveness/Behavior 

declined to the lowest number of Cases within the 

Problem Solving category.

2

1

3 REGULATORY FINDINGS OR ACCURACY CONCERNS

STAFF RESPONSIVENESS OR BEHAVIOR

OTHER ISSUES

17

(36%)

47 89 136

1

2

3 2019 & 2020

46%

21%

44%
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 25

1 OTHER ISSUES

This category includes a wide variety of industry 

requests for assistance that do not fall into the other 

two categories. The most common of the requests 

for both 2019 and 2020 related to the Division of 

Risk Management Supervision (Risk Management 

Supervision) examination topics, while the next most 

requested assistance was Bank Secrecy Act compliance 

(2019) and bank applications (2020). The Risk 

Management Supervision topics included questions 

related to the following areas of interest:

• Enforcement action compliance; 

• Assistance in understanding ratings; and 

• Examination scheduling issues, both COVID-19 

and non-COVID-19 related. 

The 2019 BSA-focused questions included discussions 

regarding examination treatment of BSA deficiencies 

and assistance in understanding and working through 

corrective actions. The 2020 bank applicationfocused questions largely dealt with questions about 

the application process and clarifying expectations 

between the applicant and the FDIC. Regional 

Ombudsmen responses were customized to each 

situation and included:

• Referring parties to the appropriate 

FDIC contacts; 

• Communicating with FDIC staff, 

confidentially on the bank’s behalf, to obtain 

clarity on the situation; and 

• Facilitating meetings between the parties. 

These meetings and further discussions that were 

facilitated by the Regional Ombudsmen served to 

reduce misunderstandings between the various parties. 

This category primarily relates to discussions 

regarding Compliance and Risk Management 

examinations. In some cases, bankers raised 

concerns that not all relevant facts were considered, 

contributing to disagreements with violation 

citations or ratings. The common theme throughout 

the majority of these cases is a lack of effective 

communication between bank management and 

examination personnel. Regional Ombudsmen 

directed their efforts on increasing and enhancing 

communication between the parties, particularly 

prior to the conclusion of the examination, when 

possible. These enhanced communication 

options included arranging follow-up meetings 

with local and regional staff, facilitating additional 

local discussions so that differences were better 

understood, and working with contacts to evaluate 

and assess their position.

2 STAFF RESPONSIVENESS OR BEHAVIOR

Cases in this category related to the 

professionalism of FDIC staff. Bankers raised 

varied concerns about behavior that included FDIC 

employees being unresponsive to bank requests, 

examination team members being inconsiderate 

of bank employees, and conduct considered to be 

unethical. Regional Ombudsmen generally dealt 

with these cases by investigating the facts and 

circumstances surrounding the allegations and 

elevating the matter (when warranted and with the 

expressed permission of the caller) to the attention 

of Executives and decision makers for action. The 

resolution of these matters was determined based 

on the specifics of the case.

3 REGULATORY MATTERS OR ACCURACY CONCERNS

CATEGORIES OF PROBLEM SOLVING

Patterns of Problem Solving Cases

INDIVIDUAL INDUSTRY CASES
26 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

227

2019 2020 2019 & 2020 REMAINING CATEGORIES OF INDUSTRY CASES

C FDICCONNECT ISSUES

D WHISTLEBLOWER-BANK PRACTICES

136

65

97

(49%)

130

(36%)

47

(24%)

89

(25%)

25

(13%)

40

(11%)

21

(11%)

27

(8%)

TOTAL INDIVIDUAL INDUSTRY CASES BY YEAR 197 358 555

B PROBLEM SOLVING

A REQUESTS FOR INFORMATION

E OTHER RECOMMENDATIONS AND FEEDBACK

48

7

(3%)

72

(20%) 79

C-E. Remaining Categories of Industry Cases

INDUSTRY CASES DURING 2019 & 2020

D WHISTLEBLOWER-BANK PRACTICES

C FDICCONNECT ISSUES E OTHER RECOMMENDATIONS & FEEDBACK

This category primarily related to technical assistance 

requests including access issues, functionality challenges, and 

other technical difficulties related to utilizing FDICconnect; 

which is an electronic portal used to exchange documents 

securely between the FDIC and banks. In 2020, this category 

also included technical assistance requests for access issues 

related to banks completing the Post Examination Survey. 

Regional Ombudsmen resolved these issues through a 

combination of solutions including making referrals to 

technical resources, providing assistance documents, and 

connecting the individuals with technical support staff.

These cases consisted of a wide variety of allegations 

against financial institutions and their employees, and 

often originate from confidential sources including bank 

customers, bank employees, and members of the general 

public. These cases were researched and, when determined 

appropriate, referred to an examination division for review 

and follow-up or to the FDIC’s Office of the Inspector General 

for review and investigation.

Requests in this category in 2019 included individual 

recommendations related to De Novo institution 

formation, Reports of Condition and Income 

functionality, and FDIC responsiveness to new product 

development. Requests in this category for 2020 

increased significantly and the increase was centered in 

issues new to the industry (Pandemic) and new to the 

Office of the Ombudsman (PES administration). This 

category includes 38 cases with requests, comments, 

and recommendations regarding implementation of 

COVID-19 legislation, while 18 were PES requests to the 

Associate Ombudsman to discuss recently completed 

examinations. These PES follow-up calls typically stem 

from a desire to recognize the strong performance of 

the examination team; provide constructive feedback; 

or convey criticisms of certain aspects of the recently 

completed examination. For all cases that fall within 

this category, Regional Ombudsmen accumulate the 

responses and provide them to the appropriate internal 

stakeholders with responsibility over the specific 

referenced areas for consideration.
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 27

Industry Outreach Visits

SECTION E
28 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

1,274

2019 2020 2019 & 2020 CATEGORIES OF FEEDBACK ITEMS

A EXAMINATION MATTERS 

TOTAL FEEDBACK ITEMS BY YEAR 1,302 1,295 2,597

TOTAL INDUSTRY OUTREACH VISITS BY YEAR 524 529 1,053

Overview of Industry Outreach Visits

INDUSTRY OUTREACH VISITS

5

Many of the Regulatory Process Feedback Items and comments dealt with banks converting charters and the reasons behind those decisions. 

Other comments addressed a wide variety of subjects including claims of unfair competition against tax-advantaged entities, lending limits that 

are viewed as restrictive, and other references to the effectiveness or ineffectiveness of other agencies with which banks interact. 

D REGULATORY PROCESS5 33

B OTHER REGULATORY MATTERS

C BANKING ENVIRONMENT

769

521

Regional Ombudsmen conducted 524 industry 

outreach visits to banks and industry trade 

associations in 2019 and 529 outreach contacts 

in 2020. Travel restrictions forced most of the 2020 

contacts to be conducted virtually, but the program 

remained robust and effective given the circumstances. 

The number of feedback items remained consistent 

across the years with 1,302 feedback items reported in 

2019 and 1,295 in 2020. 

With more than one thousand feedback items received 

during Industry Visits and Outreach Contacts for 

each year, the variety of items ranged in complexity 

and specificity regarding the key issues and regional 

concerns. The Office of the Ombudsman reviewed all 

feedback with care and consideration and compiled the 

items by broad, common themes and rate of frequency. 

The Pandemic, which was a significant disruptor to 

bank operations during 2020, became a frequent topic 

of discussion. Other feedback items declined during 

the year as bank management efforts and attention 

were focused on operational continuity and staff/

customer safety. This focus on dealing with the impact 

of the Pandemic was reflected in outreach feedback 

and comments.

INTERPRETING THE FEEDBACK ITEMS

PATTERNS OF FREQUENT FEEDBACK ITEMS

These feedback items represent sentiment offered 

on multiple occasions by industry representatives, 

but are not to be interpreted as being representative views of the entire banking community. 

543

(42%)

731

(57%)

482

(37%)

287

(22%)

259

(20%)

262

(20%)

18

(1%)

15

(1%)
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 29

Outreach Feedback Items Specific to 2020

INDUSTRY OUTREACH VISITS

This category included specific feedback 

related to examinations conducted on 

an entirely remote basis in 2020. The 

comments were predominantly favorable and 

included a few common themes:

• For smaller institutions, document 

scanning and uploading were viewed as 

burdensome, but somewhat offset by less 

disruption during the examination itself; 

• A communication plan established between 

the bank and examiners for the duration of 

the examination was beneficial;

• Face-to-face communication was valued and 

missed, but virtual meeting options proved 

to be effective when utilized.

COVID-19 IMPACT

This category included COVID-19 feedback as it 

related to the examination process. Comments 

received largely conveyed the following sentiment:

• Appreciation for regulatory accounting 

accommodations made for the impact of 

the Pandemic;

• Gratitude for encouraging community banks 

to work with their customers; and

• Concerns over how their actions related to he 

Coronavirus Aid, Relief, and Economic Security 

(CARES) Act, and loan modifications will be 

perceived and evaluated at future examinations.

REMOTE EXAMINATION WORK
30 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

• RISK MANAGEMENT 

EXAMINATIONS

• BANK SECRECY ACT 

REVIEWS (BSA)

• INFORMATION 

TECHNOLOGY

EXAMINATION 

PROCESS 2

DIVISION OF RISK 

MANAGEMENT

SUPERVISION (RMS)

1 BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

11

A EXAMINATION 

ISSUES

B OTHER REGULATORY

MATTERS

C BANKING

ENVIRONMENT

COVID-19 IMPACT TO

2020 BANK OPERATIONS 1

BANK

ENVIRONMENT 2

CORONAVIRUS AID, RELIEF, 

AND ECONOMIC SECURITY

(CARES) ACT

3

AGRICULTURAL

ECONOMY 4

INDUSTRY

CONSOLIDATION 5

COMPETITION FROM CREDIT 

UNIONS AND FARM CREDIT 

SYSTEM INSTITUTIONS

6

OTHER FEEDBACK

ITEMS 7

CYBER SECURITY 

CHALLENGES AND COSTS 8

TECHNOLOGY SERVICE

PROVIDER CONCERNS 9

2,597 TOTAL FEEDBACK ITEMS IN 2019 & 2020

Patterns of Frequent Feedback Items

INDUSTRY OUTREACH VISITS

DIVISION OF DEPOSITOR 

AND CONSUMER 

PROTECTION (DCP)

3

• COMPLIANCE EXAMS

AND NON-SPECIFIC

FEEDBACK

• COMMUNITY 

REINVESTMENT ACT 

(CRA) EVALUATION 

BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 31

• RISK MANAGEMENT 

EXAMINATIONS

• BANK SECRECY ACT 

REVIEWS (BSA)

• INFORMATION 

TECHNOLOGY

EXAMINATION 

PROCESS 2

DIVISION OF RISK 

MANAGEMENT

SUPERVISION (RMS)

1

B OTHER REGULATORY

MATTERS

C BANKING

ENVIRONMENT

DIVISION OF DEPOSITOR 

AND CONSUMER 

PROTECTION (DCP)

3

• COMPLIANCE EXAMS

AND NON-SPECIFIC

FEEDBACK

• COMMUNITY 

REINVESTMENT ACT 

(CRA) EVALUATION 

A EXAMINATION 

ISSUES

Feedback Items: Examination Matters

INDUSTRY OUTREACH VISITS
32 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

A. Examination Matters

EXAMINATION MATTERS FEEDBACK ITEMS

During industry outreach visits and contacts 

conducted in 2019 and 2020, Regional 

Ombudsmen received 2,597 feedback items 

including 1,274 on Examination Matters. Of those 

Examination Matters, 48% related to the Division of Risk 

Management Supervision, 27% related to Examination 

Process (General or Non-Division Specific), and 

25% related to Division of Depositor and Consumer 

Protection. Below is a breakout of Examination Matters, 

ordered by category and by year. 

B OTHER REGULATORY MATTERS

A EXAMINATION MATTERS 

C BANKING ENVIRONMENT

CATEGORIES OF FEEDBACK ITEMS

EXAMINATION MATTERS FEEDBACK ITEMS 2019 2020

TOTAL FEEDBACK ITEMS BY YEAR

TOTAL INDUSTRY OUTREACH VISITS BY YEAR

286

6

10

731

1,302 1,295 2,597

617

340

317

218

8

284

33

26

24

567

524 529 1,053

2019 & 2020

DIVISION OF DEPOSITOR AND 

CONSUMER PROTECTION (DCP) 3

• RISK MANAGEMENT EXAMINATIONS

• BANK SECRECY ACT REVIEWS (BSA)

• INFORMATION TECHNOLOGY

• COMPLIANCE EXAMINATIONS

AND NON-SPECIFIC FEEDBACK

• COMMUNITY REINVESTMENT ACT 

(CRA) EVALUATION 

2 EXAMINATION PROCESS

DIVISION OF RISK MANAGEMENT 

SUPERVISION (RMS) 1

A EXAMINATION MATTERS 1,274

281

18

16

315

(58%)

66

25

1,274 TOTAL OF FEEDBACK ITEMS THAT WERE

RELATED TO EXAMINATION MATTERS

302

(41%)

137

(25%)

203

(28%)

91

(17%)

226

(31%)

543

(42%)

731

(57%)
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 33

Of the 617 Examination Matters associated with 

the Division of Risk Management Supervision, 

the majority of Issues or 92% related to Risk 

Management Examinations. Bank Secrecy Act 

Reviews and Information Technology Examinations 

each accounted for 4% of issues reported. 

RISK MANAGEMENT EXAMINATIONS

Experiences from the most recent RMS examination 

were the focus of the comments, which were generally 

positive when relating to examination staff interactions.

Staff were most commonly referenced as professional, 

engaged, well-trained, and respectful. RMS converted 

to fully-offsite examinations (“remote examinations”) 

starting in March 2020 and feedback related to those 

remote examinations was largely positive. While remote 

examinations were generally viewed favorably, many 

industry professionals expressed a desire to have a 

portion of the examination completed in person when 

circumstances permit. The amount of desired on-site 

presence varied widely depending on many factors 

including number of bank employees, how far along the 

bank was in maintaining electronic records (particularly 

loan files), and the substance of examination findings. 

Constructive (unfavorable) commentary was sometimes 

offered in regard to the length of examinations, 

duplicative requests for examination materials, inability 

to navigate non-verbal communication, and isolated 

communication difficulties with examination staff.

BANK SECRECY ACT REVIEW (BSA)

Comments related to feedback on BSA reviews 

generally related to the following topical areas: 

cannabis and hemp; beneficial-ownership 

requirements; and suspicious activity reporting. 

There were also several commenters that 

shared their positive and constructive 

examination experiences.

INFORMATIONAL TECHNOLOGY (IT)

Comments related to recent IT examination 

experiences were generally favorable. Some 

comments under this topic included concerns over 

examiner expectations and the persistent increasing 

costs associated with IT operations and security.

RMS FEEDBACK ITEMS 2019 2020

286

6

10

731

26

24

567

2019 & 2020

• RISK MANAGEMENT EXAMINATIONS

• BANK SECRECY ACT REVIEWS (BSA)

• INFORMATION TECHNOLOGY

1 DIVISION OF RISK MANAGEMENT SUPERVISION

543 731 1,274

281

18

16

B OTHER REGULATORY MATTERS

A EXAMINATION MATTERS 

C BANKING ENVIRONMENT

CATEGORIES OF FEEDBACK ITEMS

A1. Risk Management Supervision (RMS)

EXAMINATION MATTERS FEEDBACK ITEMS

315 302 617

A EXAMINATION MATTERS

TOTAL FEEDBACK ITEMS BY YEAR 1,302 1,295 2,597
34 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Commenters in this category provided their 

general observations on the FDIC’s examination 

process and views on examination staff. The 

comments were generally positive and described 

the examination process as improving and more 

collaborative or cooperative than in the past. 

Examiners were noted as being readily available for 

providing guidance. Examination process comments 

included appreciation for the following:

• Examiners arriving at the bank familiar with 

the institution; 

• Examination work conducted offsite increased; 

• Communication with examiners was effective; 

and 

• Many bankers observed the in-person 

interaction led to relationship building, 

constructive conversations, and more fully

 vetted examination findings. 

CONSTRUCTIVE COMMENTS INCLUDED:

• Inconsistent findings by different examination 

teams and a lack of scheduled examination 

coordination between the risk and compliance 

examination teams.

• In some cases, concern was raised over the 

Report of Examination tone being more 

critical in substance than examiner comments 

conveyed during the examination

EXAMINATION PROCESS FEEDBACK ITEMS 2019 2020

731

2019 & 2020

2 EXAMINATION PROCESS

TOTAL EXAMINATION MATTERS BY YEAR 543 731 1,274

340

B OTHER REGULATORY MATTERS

A EXAMINATION MATTERS 

C BANKING ENVIRONMENT

CATEGORIES OF FEEDBACK ITEMS

A2. Examination Process

EXAMINATION MATTERS FEEDBACK ITEMS

617

137 203

315 302

91 226 317

28% TOTAL OF FEEDBACK ITEMS RELATED 

TO EXAMINATION PROCESS IN 2019 & 2020

• EXAMINATION PROCESS (PANDEMIC RELATED) N/A 26 26

GENERAL OR NON-DIVISION SPECIFIC

DIVISION OF RISK MANAGEMENT 

SUPERVISION (RMS) 1

DIVISION OF DEPOSITOR AND 

CONSUMER PROTECTION (DCP) 3
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 35

731 3 DEPOSITOR AND CONSUMER PROTECTION (DCP)

A3. Depositor & Consumer Protection (DCP)

EXAMINATION MATTERS FEEDBACK ITEMS

317

218

8

284

33

• COMPLIANCE EXAMINATIONS

AND NON-SPECIFIC FEEDBACK

• COMMUNITY REINVESTMENT ACT 

(CRA) EVALUATION 

66

25

91

(17%)

226

(31%)

B OTHER REGULATORY MATTERS

A EXAMINATION MATTERS 

C BANKING ENVIRONMENT

CATEGORIES OF FEEDBACK ITEMS

DCP FEEDBACK ITEMS 2019 2020 2019 & 2020

617 315

(58%)

302

(41%)

340 137

(25%)

203

(28%)

25% TOTAL OF FEEDBACK ITEMS THAT 

WERE RELATED TO DCP IN 2019 & 2020

Of the 317 feedback items associated with 

the Division of Depositor and Consumer 

Protection (DCP) in 2019 and 2020, the majority 

of items, 284 items, were related to compliance 

examinations and non-specific DCP feedback. The 

additional feedback items received in 2019 and 2020 

were associated with Community Reinvestment Act 

(CRA) Evaluations. DCP General or Non-Specific to 

CRA or Compliance represented 4% of the total DCP 

Examination Matters Feedback Items. 

DIVISION OF RISK MANAGEMENT 

SUPERVISION (RMS) 1

2 EXAMINATION PROCESS

A EXAMINATION MATTERS 543 731 1,274

TOTAL FEEDBACK ITEMS BY YEAR 1,302 1,295 2,597

TOTAL INDUSTRY OUTREACH VISITS BY YEAR 524 529 1,053
36 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

A3. Non-Specific DCP Feedback Items

EXAMINATION MATTERS FEEDBACK ITEMS

Feedback related to DCP in general was notably 

positive, including specific Compliance 

examinations. Commenters found examiners 

to be particularly helpful while ensuring bank staff 

understood, and could comply with, governing 

regulations. The increase in comments received during 

2020 is attributed to feedback related to a Report 

of Examination piloted during 2020. Additionally, 

there were numerous comments received about 2020 

examinations completed on a remote, offsite-only 

basis. Feedback items related to the revised Report 

pilot and those received on remote examinations were 

overwhelmingly positive. Constructive comments 

focused on extended report turnaround times, primarily 

when referencing fair lending reviews, before the bank 

received the final Report of Examination. Comments 

provided also indicated that, on occasion, examination 

staff appeared overly focused on minor issues, while 

overlooking positive measures bank management had 

accomplished. The volume of constructive or critical 

comments declined in 2020. 

COMMUNITY REINVESTMENT ACT (CRA) EVALUATIONS

Feedback related to CRA Evaluations included a variety 

of both positive and constructive comments. Positive 

feedback related to general examiner support and 

guidance, including assisting institution management in 

understanding evaluation criteria. Constructive comments 

expressed frustration in understanding the following:

• Performance expectations when transitioning 

from the examination procedures of one 

asset-size threshold to the next (i.e., Small 

Institutions, Intermediate Small Institutions, 

Large Institutions, and Institutions with 

Strategic Plans);

• Documentation expectations necessary 

to receive CRA credit; and

• Subjective criteria for certain loans or 

community investments to qualify for 

consideration under the Act.

COMPLIANCE EXAMINATIONS & NON-SPECIFIC FEEDBACK

A EXAMINATION 

ISSUES

• RISK MANAGEMENT 

EXAMINATIONS

• BANK SECRECY ACT 

REVIEWS (BSA)

• INFORMATION 

TECHNOLOGY

EXAMINATION 

PROCESS 2

DIVISION OF RISK 

MANAGEMENT

SUPERVISION (RMS)

1

DIVISION OF DEPOSITOR 

AND CONSUMER 

PROTECTION (DCP)

3

• COMPLIANCE EXAMS

AND NON-SPECIFIC

FEEDBACK

• COMMUNITY 

REINVESTMENT ACT 

(CRA) EVALUATION 
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 37

A EXAMINATION

ISSUES

BANKING

ENVIRONMENT

Feedback Items: Other Regulatory Matters

INDUSTRY OUTREACH VISITS

B C OTHER REGULATORY

MATTERS

BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

11 BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS
38 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

1 BANK APPLICATIONS

2 CURRENT EXPECTED CREDIT LOSSES (CECL)

3 REGULATORY MATTERS - OTHER

4 BANK SECRECY ACT (BSA)

5 FDIC OPERATIONS

APPEALS PROCESS AND THE SUPERVISION 

APPEALS REVIEW COMMITTEE 6

7 REGULATION BURDEN

8 REGULATION Z TRUTH IN LENDING (REG Z)

9 COMMUNITY REINVESTMENT ACT (CRA) 

AND CRA MODERNIZATION

10 HOME MORTGAGE DISCLOSURE ACT (HMDA)

11 BROKERED DEPOSITS AND INTEREST RATE RESTRICTIONS

B. Other Regulatory Matters

OTHER REGULATORY MATTERS FEEDBACK ITEMS

A EXAMINATION MATTERS C BANKING ENVIRONMENT

2019 2020

FREQUENCY OF FEEDBACK ITEMS

TOTAL FEEDBACK ITEMS BY YEAR

TOTAL INDUSTRY OUTREACH VISITS BY YEAR

731

1,302 1,295 2,597

524 529 1,053

2019 & 2020

B OTHER REGULATORY MATTERS

B OTHER REGULATORY MATTERS 482 287 769

22%

14%

13%

11%

9%

8%

6%

5%

4%

3%

5%

Of the 2,597 feedback items received in 2019 and 

2020, 769 related to the Other Regulatory Matters

category. Below is a breakdown of those items, 

ordered by frequency and percentage:

OTHER REGULATORY MATTERS 30%

PERCENTAGE OF TOTAL FEEDBACK ITEMS 

RELATED TO OTHER REGULATORY 

MATTERS IN 2019 & 2020
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 39

CECL is an accounting standard that changes how financial 

institutions account for expected credit losses. Feedback was 

consistently focused on the opinion that this accounting rule change 

is not necessary for privately held community banks. 

Other comments on CECL included the following:

• Limited or no perceived benefit for smaller or community 

institutions;

• CECL implementation was a form of regulatory burden; and

• Uncertainty as to how examiners will assess bank’s efforts and 

methodologies. 

While the comments were generally negative, a large number 

of commenters stated they have initiated strategies toward 

implementation including collecting data, testing models, and in 

many cases running parallel systems to their current Allowance for 

Loan and Lease Losses methodology. 

B OTHER REGULATORY

MATTERS

BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

11

Views expressed regarding FDIC’s processing of 

bank applications were generally positive. Banks completing 

acquisitions and filing merger applications were part of the 

sample and comments specific to that process were generally 

complimentary. Application processing was frequently described 

as being “smooth” and “straightforward”; Case Managers 

were routinely complimented for their efforts processing the 

applications; communication was noted as being favorable; 

and applications were generally processed in a timely manner. 

Applications processed during the pandemic continued to be 

processed timely and with strong communication maintained 

throughout the process.

Several commenters referenced new bank applications (De Novo), 

with positive and constructive feedback on the process provided. 

Commenters were generally satisfied with the support provided by 

the agency to the process and the utility of the De Novo handbook 

while navigating the application process. Pre-filing meetings 

were noted as being particularly beneficial and contributed to a 

transparent process. However, several commenters expressed 

frustrations regarding the De Novo process including the length of 

time for feedback on correspondence and information submitted, 

expectations to develop comprehensive written policies prior to 

executive staff being fully in place, and the overall timeframe for 

applications to be accepted or approved.

1 BANK APPLICATIONS

2 CURRENT EXPECTED CREDIT LOSSES

B1–2. Bank Applications and Credit Loss

OTHER REGULATORY MATTERS FEEDBACK ITEMS

BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS
40 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

B OTHER REGULATORY

MATTERS

BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

11

B3–5. Bank Secrecy and FDIC Operations

OTHER REGULATORY MATTERS FEEDBACK ITEMS

5 FDIC OPERATIONS

This category includes a wide variety of topics that do not fall into 

the other ten categories. They are most significantly represented by 

comments regarding regulation burden, Reports of Condition and 

Income simplification efforts, Capital rules, and some feedback on 

special purpose bank charters.

3 REGULATORY MATTERS (OTHER)

4 BANK SECRECY ACT (BSA)

Feedback received in outreach contacts related to BSA related 

to the challenge and burden of complying with the regulations 

generally, with particular emphasis on three areas:

• Beneficial Ownership; 

• Cannabis/Hemp; and 

• Currency Transaction Report (CTR) thresholds. 

Common sentiments from the industry were that Beneficial 

Ownership requirements were burdensome, the documentation was 

not the responsibility of a bank (aligning more with each jurisdictions’ 

Secretary of State), and that customers do not understand the need 

for providing the information. Comments regarding a bank’s ability 

to provide financial services to the cannabis and hemp industries, as 

well as ancillary businesses, largely conveyed the sentiment that the 

industry participants are seeking legislative and regulatory clarity. 

Bank executives continue to express a desire for additional guidance 

from the FDIC on regulatory expectations for banking cannabis and 

hemp customers beyond that outlined in the prevailing FinCEN 

guidance. Also, CTR filing thresholds were frequently noted as being 

too low and a burden on the industry. Commenters stated that, given 

the length of time and inflation since this regulation was enacted, the 

reporting threshold should be raised.

These comments primarily captured positive feedback on the 

FDIC Operations including the FDIC Chairman’s (Trust Through 

Transparency) initiative along with the following:

The Office of the 

Ombudsman assuming 

primary responsibility 

for the Post-Examination 

Survey process

Support and 

communication 

provided to the 

industry throughout 

the Pandemic

Working relationships with 

local FDIC examiners and 

Regional Management’s 

willingness to participate 

in outreach/training events

Directors Colleges, 

Industry education, 

and website-published 

training videos

BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 41

This category consisted of feedback regarding the Guidelines for 

Appeals of Material Supervisory Determinations, also referred to as the 

“Appeals” process. This process was initially established by the Riegle 

Act, which required the FDIC to establish an independent intra-agency 

appellate process to review material supervisory determinations 

made at insured depository institutions that it supervises. The FDIC 

established the Supervision Appeals Review Committee (SARC) to 

review such appeals of material supervisory determinations. 

In 2019, the Office of the Ombudsman conducted listening sessions 

in each Region in order to gather ideas from the industry for 

improving the Appeals process. Comments received by the Office of 

the Ombudsmen in 2019 relative to the Appeals process expressed 

frustration and a desire for more transparency and a less intimidating 

atmosphere. This feedback was utilized in developing a Notice and 

Request for Comment on the proposed amendment to the Guidelines 

for Appeals of Material Supervisory Determinationsapproved by 

the FDIC Board of Directors on August 21, 2020. Feedback received 

by the Office in 2020 largely focused on the proposal to amend the 

guidelines. Feedback was generally positive and commenters felt the 

modifications would make the process more independent, inclusive, 

and transparent. 

6

B6–8. Appeals Process and Regulations

OTHER REGULATORY MATTERS FEEDBACK ITEMS

Comments from bank executives related to Regulation Z focused 

almost entirely on the TILA-RESPA Integrated Disclosure Rule (TRID). 

These executives frequently stated the disclosures fall short of helping 

consumers as they remain difficult to understand. There were also 

comments received regarding the expense of providing the disclosures, 

their complexity, and difficulty in completing them accurately. Bank 

executives from some smaller financial institutions commented that 

originating home mortgage loans has become challenging due to 

perceived compliance risk, complexity surrounding TRID, and other real 

estate loan disclosures and a lack of available staff. A small number 

of banks indicated they have ceased originating home loans due to 

disclosures and other regulatory requirements.

8 REGULATION Z TRUTH IN LENDING (REG Z)

Comments focused on the burden of the time, expense, and staffing 

needed to comply with the number of relevant regulations. Some 

comments indicate these resource needs led to increased usage of 

consultants, which elevated overhead expense without an increase 

in revenues. Some commenters appreciated a recent absence of 

complicated new regulations, which provided some stability to 

banks’ operating environment, but many stated more needed to 

be done to reduce regulation burden. As an option, numerous 

respondents advocated for stratifying the regulatory structure to 

better match regulations to the size and complexity of institutions.

7 REGULATION BURDEN

B OTHER REGULATORY

MATTERS

BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS 11

APPEALS PROCESS AND THE SUPERVISION 

APPEALS REVIEW COMMITTEE
42 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

The preponderance of feedback on brokered deposits and 

interest rate restrictions dealt with suggestions to modify and 

simplify the FDIC’s rate calculation. Other bankers requested 

eliminating geographic distinction of deposits and recommended 

the FDIC work to remove the perceived stigma associated with 

using brokered deposits. Several expressions of appreciation 

were also received in 2019 for removing reciprocal deposits from 

the definition of brokered deposits.

11 BROKERED DEPOSITS, INTEREST RATE RESTRICTIONS

Feedback on HMDA struck a consistent theme that compliance 

was costly, and the regulation placed a burden on institutions. 

Bankers opined that there is a perceived regulatory expectation 

for perfection in this area, necessitating an extensive amount of 

staff time and expense to meet the standard. Collection of the 

data and ensuring its completeness and accuracy was viewed as 

an extensive use of manpower. Several executives from small 

community banks expressed concern that the limited number of 

applicable loans that they originate does not justify the cost of 

collection, with another frequent concern being that there are too 

many data elements.

10 HOME MORTGAGE DISCLOSURE ACT (HMDA)

Comments and feedback received on the CRA were primarily 

centered on efforts by regulatory authorities to modernize the Act. 

A common theme was conveyed that the CRA is outdated and does 

not account for technology or technological advances in deposit 

gathering alternatives. While many contacts were looking forward 

to a CRA update, disappointment was expressed that the Federal 

Banking Agencies did not seem to be working together on these 

modification efforts. Commenters felt less subjectivity and more 

specific guidance on what qualifies for credit under the revised rules 

would be beneficial. Bankers stated that under the current process, 

some meaningful efforts and activities were not considered when 

evaluating a bank’s performance under the Act.

COMMUNITY REINVESTMENT ACT (CRA) 

AND CRA MODERNIZATION 9

B OTHER REGULATORY

MATTERS

BANK 

APPLICATIONS 1

CURRENT EXPECTED 

CREDIT LOSSES (CECL) 2

REGULATORY MATTERS

(OTHER) 3

BANK SECRECY

ACT (BSA) 4

FDIC

OPERATIONS 5

APPEALS PROCESS AND 

THE SUPERVISION APPEALS 

REVIEW COMMITTEE

6

REGULATION

BURDEN 7

REGULATION Z (REG Z)

TRUTH IN LENDING 8

COMMUNITY REINVESTMENT 

ACT (CRA) AND CRA 

MODERNIZATION

9

HOME MORTGAGE

DISCLOSURE ACT

(HMDA)

10

BROKERED DEPOSITS AND 

INTEREST RATE RESTRICTIONS 11

B9–11. CRA and Interest Rate Restrictions

OTHER REGULATORY MATTERS FEEDBACK ITEMS
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 43

A EXAMINATION

ISSUES

Feedback Items: Banking Environment

INDUSTRY OUTREACH VISITS

C BANKING

ENVIRONMENT

B OTHER REGULATORY

MATTERS

COVID-19 IMPACT TO

2020 BANK OPERATIONS 1

BANKING

ENVIRONMENT 2

CORONAVIRUS AID, RELIEF, 

AND ECONOMIC SECURITY

(CARES) ACT

3

AGRICULTURAL

ECONOMY 4

INDUSTRY

CONSOLIDATION 5

COMPETITION FROM CREDIT 

UNIONS AND FARM CREDIT 

SYSTEM INSTITUTIONS

6

OTHER FEEDBACK

ITEMS 7

CYBER SECURITY 

CHALLENGES AND COSTS 8

TECHNOLOGY SERVICE

PROVIDER CONCERNS 9
44 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

1

2

3

4

5

6

7

8

9

A EXAMINATION MATTERS C BANKING ENVIRONMENT

2019 2020

FREQUENCY OF FEEDBACK ITEMS

TOTAL FEEDBACK ITEMS BY YEAR

TOTAL INDUSTRY OUTREACH VISITS BY YEAR

731

1,302 1,295 2,597

524 529 1,053

2019 & 2020

B OTHER REGULATORY MATTERS

C BANKING ENVIRONMENT

Of the 2,597 feedback items received in 2019 and 

2020, 521 related to the Banking Environment 

category. Below is a breakdown of those items, 

ordered by frequency and percentage:

 BANKING ENVIRONMENT 20%

PERCENTAGE OF TOTAL FEEDBACK ITEMS 

THAT WERE RELATED TO BANKING 

ENVIRONMENT IN 2019 & 2020

C. Banking Environment

BANKING ENVIRONMENT FEEDBACK ITEMS

COVID-19 IMPACT TO 2020 BANK OPERATIONS 26%

BANKING ENVIRONMENT 21%

COVID-19 CARES ACT (PAYCHECK PROTECTION PROGRAM) 14%

AGRICULTURAL ECONOMY 9%

INDUSTRY CONSOLIDATION 9%

COMPETITION FROM CREDIT UNIONS/FARM CREDIT SYSTEM INSTITUTIONS 9%

OTHER FEEDBACK ITEMS 5%

CYBERSECURITY CHALLENGE AND COSTS

TECHNOLOGY SERVICE PROVIDER CONCERNS 3%

4%

259 262 521
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 45

This category captures comments related to the 

CARES Act with the majority focused on the Paycheck 

Protection Program (PPP) available to small- and 

medium-sized businesses. Comments covered feedback 

on bank experiences during the origination and 

forgiveness phases of the program. One common theme 

conveyed was a lack of clear guidance at the outset of 

the program. When guidance began to be disseminated, 

commenters described it as conflicting or unclear during 

the various stages of the process. As banks became 

more familiar and experienced with the PPP program, 

these comments decreased. Also conveyed were 

challenges and successes in using the Small Business 

Association’s portal to originate the loans. Some 

commenters conveyed they chose not to participate 

in the PPP program due to their limited staffing and 

perceived administrative hurdles; however, in those 

cases referrals of applicants to competitors were noted. 

Banks actively participating in the PPP described pride 

in their bank’s ability to utilize the program to benefit 

their local communities and felt it displayed the value of 

community banks. 

Comments included in this category relate to the general banking 

environment. Common topics brought forth by the commenters 

include the following:

• Fierce competition for deposits in 2019, which reversed to an 

overall increase in deposit levels in 2020;

• Very competitive loan markets in 2019 that shifted into generally 

tepid loan demand throughout 2020, with the exception of 

mortgage loan originations, which remained robust;

• In 2019, some markets were noted as being overbanked, 

while others were suffering from rural depopulation whereby 

long-term deposits within the community eventually follow 

population trends and transfer to more populous areas; and

• In 2020, excess liquidity, stagnant loan demand, and low interest 

rates combined to put downward pressure on net income. 

Comments in this category correlate to the impact the Pandemic 

had on financial institutions’ operations. Topics included restricting 

customer access to lobbies while maintaining drive-thru lanes, mobile 

banking applications, automated teller machines, virtual tellers, and 

distanced meetings by appointment only.

Contacts also reported installation of personal protective 

equipment and implementation of social distancing requirements 

since the start of the Pandemic. Bank staffing became a critical issue 

to ensure operations could be sustained and many banks moved to 

full or partial telework for employees. Rotating shifts of workers 

were also commonly reported in attempts to keep a healthy core 

staff for operational continuity. Short-term crisis mode topics 

included coin shortages, an inability to get deeds recorded, and 

the rapid development of electronic signature protocols. 

1

2 BANKING ENVIRONMENT

C1–3. Coronavirus Impact and Relief

BANKING ENVIRONMENT FEEDBACK ITEMS

COVID-19 IMPACT TO 2020 BANK OPERATIONS

C BANKING

ENVIRONMENT

COVID-19 IMPACT TO

2020 BANK OPERATIONS 1

BANKING

ENVIRONMENT 2

CORONAVIRUS AID, RELIEF, 

AND ECONOMIC SECURITY

(CARES) ACT

3

AGRICULTURAL

ECONOMY 4

INDUSTRY

CONSOLIDATION 5

COMPETITION FROM CREDIT 

UNIONS AND FARM CREDIT 

SYSTEM INSTITUTIONS

6

OTHER FEEDBACK

ITEMS 7

CYBER SECURITY 

CHALLENGES AND COSTS 8

TECHNOLOGY SERVICE

PROVIDER CONCERNS 9

3 CORONAVIRUS AID, RELIEF, AND ECONOMIC SECURITY (CARES) ACT
46 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

3%

Challenges within the agricultural economy were frequently 

mentioned, including periods of depressed commodity prices, 

ongoing cash flow challenges, and high levels of carryover operating 

debt for a segment of their bank’s loan portfolio. Offsets to these 

negatives included substantial government payments in 2020 and 

stable to strong farm real estate values.

4 AGRICULTURAL ECONOMY

Comments on industry consolidation attributed the decline in the 

number of banks to several causes: regulatory burden, competition 

from other financial service providers, aging ownership, difficulty 

identifying and retaining qualified management, and expenses related 

to technology and cybersecurity.

Frustrations were expressed about the perceived competitive 

advantages of Credit Unions and Farm Credit System Institutions. 

Comments frequently referenced these competitors’ ability to offer 

high deposit rates and low loan rates due to their tax-exempt status, 

and not having to comply with the Community Reinvestment Act. 

Commentors identified these benefits as being unfair advantages 

over community banks. Credit Unions acquiring banks were also the 

subject of some comments as these acquisitions were perceived as 

aggressive efforts by Credit Unions to increase their market share.

5 INDUSTRY CONSOLIDATION

COMPETITION FROM CREDIT UNIONS AND 

FARM CREDIT SYSTEM INSTITUTIONS 6

Comments reflect that cybersecurity efforts are ongoing and necessary, yet expensive to sustain. There was understanding that the importance of protecting information and bank assets from cyber-attacks was critical, but the 

challenges and associated cost do not decline. Respondents also conveyed the need to remain diligent given the 

risks present in the current operating environment.

Feedback on Technology Service Providers generally consisted of comments that the industry was reliant upon a 

small number of firms, leading to increased costs, decreased offerings, and impacts to service responsiveness. The 

long duration of vendor contracts and perceived inflexibility from Technology Service Providers were also concerns 

mentioned by some bankers.

8 CYBERSECURITY CHALLENGES AND COSTS

9 TECHNOLOGY SERVICE PROVIDER CONCERNS

Other Feedback Items represents 5% of the total feedback items in the 

Banking Environment category of comments received during Industry 

Outreach Visits. This category includes a wide variety of topics that do 

not fall into the other eight Banking Environment categories.

7 OTHER FEEDBACK ITEMS

C BANKING

ENVIRONMENT

COVID-19 IMPACT TO

2020 BANK OPERATIONS 1

BANKING

ENVIRONMENT 2

CORONAVIRUS AID, RELIEF, 

AND ECONOMIC SECURITY

(CARES) ACT

3

AGRICULTURAL

ECONOMY 4

INDUSTRY

CONSOLIDATION 5

COMPETITION FROM CREDIT 

UNIONS AND FARM CREDIT 

SYSTEM INSTITUTIONS

6

OTHER FEEDBACK

ITEMS 7

CYBER SECURITY 

CHALLENGES AND COSTS 8

TECHNOLOGY SERVICE

PROVIDER CONCERNS 9

C4–9. Agricultural Economy and Other

BANKING ENVIRONMENT FEEDBACK ITEMS
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 47

Public Inquiries and Referrals

SECTION F
48 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

General Public Inquiries

The FDIC logo is viewed as a symbol of confidence 

when the public interacts with banks, deals with 

bank-related issues, and has banking questions. 

While the FDIC’s main website offers answers and 

references for the most common consumer questions, 

many consumers and members of the general public 

contact the Office of the Ombudsman with a broad 

range of inquiries, comments, and complaints. 

Before the Office of the Ombudsman becomes involved 

with an issue, established processes are first given an 

opportunity to work. Depending on the optimal course 

of action to assist inquirers, Ombudsman Specialists 

and Regional Ombudsmen identify stakeholders’ 

issues and expectations, explain processes, provide 

publicly available information, and make referrals to 

appropriate internal divisions or external resources.

General public inquiries typically range from complex 

issues that require research or consultation, to 

assistance referrals to appropriate parties internal 

or external to the FDIC. While these inquiries were 

common in 2019 and continued in 2020, the impact of 

the Pandemic created a notable increase in the number 

of public inquiries. Specifically, public inquiries to the 

Office of the Ombudsman increased by 57% in 2020. 

This increase primarily related to matters that were 

referred to Primary Federal Regulators external to the 

FDIC or for matters that were outside the purview of 

the FDIC. Contacts to the Office, which were referred 

elsewhere, experienced a dramatic increase of 75% 

from 2019 levels. Pandemic-related inquiries covered 

a wide range of challenges being faced by the general 

public including those related to stimulus checks, loan 

payment deferrals, unemployment insurance, the SBA, 

Cares Act, and access to bank facilities to name a few. 

The Office was successful in getting individuals to the 

needed information source whenever possible.

BROAD RANGE OF INQUIRIES:

For matters between bank customers and their 

financial institutions, Ombudsman Specialists 

referred the customer to the primary Federal 

regulator, including the FDIC’s Division of Depositor 

and Consumer Protection’s Consumer Response 

Center (CRC). While the FDIC provides deposit 

insurance to all banks, it only supervises statechartered banks that are not members of the Federal 

Reserve System. The CRC investigates consumer 

complaints involving FDIC-supervised banks to 

ensure consumers receive the protections provided 

by Federal consumer protection law, including rules 

addressing unfair and deceptive practices. 

COMPLAINTS AGAINST BANKS

Questions related to asset disposition and 

receivership issues at closed banks were referred, 

answered, or resolved in consultation with the FDIC’s 

Division of Resolutions and Receiverships. 

FAILED BANK MATTERS

Consumer inquiries related to Federal Deposit 

Insurance were referred to the FDIC’s Division of 

Depositor and Consumer Protection Deposit 

Insurance Group. 

DEPOSIT INSURANCE QUESTIONS

Questions related to FDIC processes and regulatory 

matters were usually researched and answered, or 

referred to the responsible Subject Matter Expert, if 

confidentiality was not requested. 

FDIC PROCESSES

CUSTOMER INQUIRIES AND FEEDBACK

TOP FOUR AREAS OF INQUIRIES:
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 49

CUSTOMER INQUIRIES AND FEEDBACK

OTHER MATTERS

1,618 TOTAL OF PUBLIC INQUIRIES IN 2019

REFERRALS TO EXTERNAL RESOURCES

737

165

82% were referrals to the 

Primary Federal Regulator 

(CFPB, FRB, OCC, or NCUA)

18% were matters that were 

outside the purview of FDIC 

and were referred elsewhere

INTERNAL

716

EXTERNAL

902

82%

18%

INDUSTRY-RELATED REFERRALS

Determining Optimal Course of Action

REFERRALS TO PRIMARY FEDERAL REGULATORS

For contact information, please see Section J for complete Directory of Primary Federal Regulators. 

OTHER MATTERS

908

668

58% were referrals to the 

Primary Federal Regulator 

(CFPB, FRB, OCC, or NCUA)

42% were matters that were 

outside the purview of FDIC 

and were referred elsewhere

INTERNAL

968

EXTERNAL

1,576

58%

42%

INDUSTRY-RELATED REFERRALS

2,544 TOTAL OF PUBLIC INQUIRIES IN 2020
50 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

FDIC Matters Resolved Internally: 2019

CUSTOMER INQUIRIES AND FEEDBACK

320

159

88

79

70

represent questions, requests or 

comments related to FDIC process 

or regulatory matters (We assisted, 

researched, and answered)

represent disputes between 

FDIC-supervised banks and 

bank customers (We referred 

to Consumer Response 

Center or back to an

FDIC-Supervised bank)

represent inquiries related to 

bank closings (We researched 

and answered or referred to DRR)

represent inquiries 

related to Deposit Insurance 

(We referred to Deposit Insurance Group, or Electronic 

Deposit Insurance Estimator, 

or researched the answer)

represent whistleblower 

allegations against 

FDIC-supervised 

financial institutions

(We alerted the responsible 

agency or otherwise 

assisted the caller)

CATEGORIES OF INTERNAL RESOLUTIONS

INTERNAL

716

EXTERNAL

902

45%

22% 12%

10%

11%

BANK AND CUSTOMER DISPUTES

RESEARCH INQUIRIES

BANK CLOSINGS

DEPOSIT INSURANCE

WHISTLEBLOWER
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 51

FDIC Matters Resolved Internally: 2020

CUSTOMER INQUIRIES AND FEEDBACK

414

224

78

146

106

represent questions, requests or 

comments related to FDIC process 

or regulatory matters (We assisted, 

researched, and answered)

represent disputes between 

FDIC-supervised banks and 

bank customers (We referred 

to Consumer Response 

Center or back to an

FDIC-Supervised bank)

represent inquiries related to 

bank closings (We researched 

and answered or referred to DRR)

represent inquiries 

related to Deposit Insurance 

(We referred to Deposit Insurance Group, or Electronic 

Deposit Insurance Estimator, 

or researched the answer)

represent whistleblower 

allegations against 

FDIC-supervised 

financial institutions

(We alerted the responsible 

agency or otherwise 

assisted the caller)

CATEGORIES OF INTERNAL RESOLUTIONS

INTERNAL

968

EXTERNAL

1,576

43%

23% 8%

11%

15%

BANK AND CUSTOMER DISPUTES

RESEARCH INQUIRIES

BANK CLOSINGS

DEPOSIT INSURANCE

WHISTLEBLOWER
52 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Customer Satisfaction Survey

The Chief Executive Officer of a bank is invited 

to complete an online Customer Satisfaction 

Survey (“Survey”) after a Regional Ombudsman 

conducts an outreach contact with the bank. 

The Survey is used to gather feedback on the 

effectiveness of the outreach program in promoting the 

awareness and services of this Office. Survey results 

are administered by the FDIC Division of Insurance and 

Research and provided to this Office, on an annual 

basis, without disclosing the identity of the individual 

banks that completed the Survey. For 2019 and 2020, 

291 and 323 banks, respectively, were invited to 

participate in the survey. The Survey results are as 

follows:

CUSTOMER INQUIRIES AND FEEDBACK

614 TOTAL NUMBER OF BANKS INVITED TO 

PARTICIPATE IN THE 2019 AND 2020 SURVEYS 

FREQUENCY OF KEY SURVEY RESPONSES:

The Survey’s responses 

continue to indicate this 

Office’s overall success 

in conveying its message 

to the financial industry 

through outreach. 

Outreach also provides an 

important opportunity 

and means for bankers to 

communicate concerns 

directly to the FDIC.

of the respondents were aware of the Office’s 

services before the outreach contact

of the respondents would utilize the services of 

the Office of the Ombudsman if needed

of the respondents rated their experience 

of these services as either “Mostly” or “Very 

Effective”

3

2

1

of the respondents rated the Regional Ombudsmen’s ability to describe their services and role 

as either “Mostly” or “Very Effective”

4

5

81%

2019

of the respondents rated the professionalism of 

the Regional Ombudsmen and their knowledge 

about the function of the FDIC as “Good” or 

“Very Good”

85%

2020

99%

2019

99%

2020

92%

2019

82%

2020

99%

2019

98%

2020

100%

2019

100%

2020
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 53

“The Regional Ombudsman has done an 

excellent job of reaching out to make us aware 

of services available. The Regional Ombudsman 

has been a good resource, and I am very pleased 

to know that I could contact the Regional 

Ombudsman in the event that it was necessary. 

We view our relationship with the FDIC as a 

partnership, and the Regional Ombudsman is an 

important role in the relationship!”

“Representative was 

very knowledgeable 

and explained the 

services offered. 

Appreciate that the 

Regional Ombudsman 

took time to visit 

community banks 

in person.”

PROFESSIONAL, INFORMATIVE, OR GOOD LISTENER

SURVEY FEEDBACK ON THE REPRESENTATIVE

“The Regional 

Ombudsman was 

very personable and 

respectful of my time.”

Open-Ended Survey Responses

CUSTOMER INQUIRIES AND FEEDBACK

APPRECIATION FOR REPRESENTATIVE’S SERVICE

GENERAL FEEDBACK ON THE OUTREACH VISIT

Chief Executive Officers of banks were invited to 

complete online Customer Satisfaction Surveys, 

including an opportunity to provide open-ended 

responses and feedback in the following categories: 

“I appreciate the service 

that the Office of the 

Ombudsman provides to 

small community banks.”

“We had a great conversation and dialogue 

regarding the industry, responsibilities, and 

past experiences with Examiners. At times, it is 

great to be reminded that we have access to the 

Ombudsman even if it may not be something we 

would think we need for some situations.”

HELPFUL VISIT OR ENJOYED MEETING

FEEDBACK ON QUALITY OF THE OUTREACH VISIT

“While I had heard of the Ombudsman’s Office, 

this visit gave me a better understanding of how 

it works in action and gave me a higher degree 

of comfort in using the service should the need 

arise in the future.”
54 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Contact FDIC’s Office of the Ombudsman

SECTION G
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 55

General Contact Information

FEDERAL DEPOSIT INSURANCE CORPORATION (FDIC)

https://www.fdic.gov/about/ombudsman/

 (877) 275-3342

 ombudsman@fdic.gov

The FDIC Office of the Ombudsman is a confidential, neutral and 

independent source of information and FDIC assistance to anyone 

affected by the FDIC in its regulatory, resolution, receivership, or asset 

disposition activities. If you have a problem or complaint with the 

FDIC that is not involved in litigation, arbitration, or mediation, you 

may contact the Office of the Ombudsman for confidential assistance. 

Our office will work with other FDIC divisions and offices as a liaison to 

address your issue.
56 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Senior Management

BIOGRAPHIES

Director

M. ANTHONY LOWE

 (312) 382-6777

mlowe@fdic.gov

Anthony joined the FDIC in 1985. He was appointed to 

his current position, FDIC Ombudsman and Director 

of the Office of the Ombudsman by the FDIC Board 

of Directors in May 2017. Prior to this appointment, 

Anthony served as an Assistant Regional Director, 

Deputy Regional Director, Case Manager, Bank 

Examiner, Bank Secrecy Act Subject Matter Expert, and 

Fraud Specialist. He also served as an Regional Director 

for the FDIC’s Chicago Region for almost nine years. 

Anthony has led a major initiative relative to identifying 

strategies for improving the FDIC’s oversight and 

technical assistance programs for minority depository 

institutions. Additionally, Anthony has made numerous 

presentations, on financial-related issues, to both 

large and small groups of bankers and regulators. He 

has also held discussions with international groups 

of senior level bankers and supervisors in Europe 

and Asia regarding problem bank and contingency 

planning issues. Anthony graduated from Arkansas 

State University with a degree in Finance. He graduated, 

with honors, from the Graduate School of Banking of 

the South at LSU, and attended the African-American 

Leadership Institute at UCLA.

HEADQUARTERS

3501 Fairfax Drive

Arlington, VA 22226 

Associate Ombudsman

AMY BROWN

 (312) 382-6770

 ambrown@fdic.gov

HEADQUARTERS

3501 Fairfax Drive

Arlington, VA 22226 

Amy began her career with the FDIC in 1991 as a 

Risk Management Bank Examiner, served as a 

Supervisory Examiner, and assumed various roles 

before accepting her current position as Associate 

Ombudsman in 2019. Amy has completed many 

details and special assignments during her more 

than 28 years with the FDIC, including Acting 

Assistant Regional Director, Acting Case Manager, 

and Acting Field Supervisor. Amy has also served as 

an instructor at the FDIC core examination schools, 

Special Assistant to the Ombudsman, and as the 

Chairman of the Supervisory Examiner Council. Amy 

has a Bachelor’s degree in Business Administration/

Finance from the University of Wisconsin-Whitewater, 

is a graduate of the Graduate School of Banking, 

Madison, Wisconsin, and is a Certified Organizational 

Ombudsman Practitioner (CO-OP®) by the 

International Ombudsman Association.
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 57

Regional Ombudsmen

Regional Ombudsman

CHARMION HALEY

 (678) 916-2188

chaley@fdic.gov

ATLANTA REGION

10 10th Street NE

Atlanta, GA 30309

Georgia, Alabama, Florida, 

South Carolina, North Carolina, 

West Virginia, and Virginia

Regional Ombudsman

DAN MARCOTTE

 (312) 382-6908

dmarcotte@fdic.gov

CHICAGO REGION

300 South Riverside Plaza

Chicago, IL 60606

Illinois, Indiana, Kentucky, 

Michigan, Ohio, and Wisconsin

Regional Ombudsman

MARVIN PAYNE

 (972) 761-2301

 mpayne@fdic.gov

DALLAS REGION

1601 Bryan St

Dallas, TX 75201

Arkansas, Colorado, Louisiana, 

Mississippi, New Mexico, Texas, 

Oklahoma, and Tennessee

Regional Ombudsman

BRENT KLANDERUD

 (816) 234-8532

 bklanderud@fdic.gov

KANSAS CITY REGION

1100 Walnut St

Kansas City, MO 64106

Iowa, Kansas, Minnesota, 

North Dakota, South Dakota, 

Missouri, and Nebraska 

Regional Ombudsman

SHERRYANN NELSON

 (917) 320-2532

 shnelson@fdic.gov

NEW YORK REGION

350 5th Avenue

New York, NY 10118

Connecticut, Delaware, District 

of Columbia, Maryland, Massachusetts, New Hampshire, New 

Jersey, New York, Maine, Pennsylvania, Puerto Rico, Rhode Island, 

Vermont, and Virgin Islands

Regional Ombudsman

KIRK DANIELS

 (415) 808-8175

 kdaniels@fdic.gov

SAN FRANCISCO REGION

25 Jessie St

San Francisco, CA 94105

Alaska, Arizona, California, 

Hawaii, Idaho, Montana, Nevada, 

Oregon, Utah, Washington, 

Wyoming, Guam, and the 

Federated State of Micronesia
58 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Federal Ombudsmen Directory

SECTION H
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 59

Federal Ombudsmen Directory

CONSUMER FINANCIAL PROTECTION BUREAU (CFPB)

www.consumerfinance.gov/ombudsman/

 (855) 830-7880

 CFPBOmbudsman@cfpb.gov

The CFPB Ombudsman’s Office is an independent, impartial, and 

confidential resource that assists Ombudsman’s consumers, financial 

entities, consumer or trade groups, and others in informally resolving 

process issues arising from CFPB activities. Contact us if you have not 

resolved your process issue after connecting with the CFPB directly, 

or to keep your concerns confidential. We may assist, for example, by: 

facilitating discussions, brainstorming options, and providing feedback 

and recommendations to the CFPB.

FEDERAL RESERVE BOARD (FRB)

https://www.federalreserve.gov/aboutthefed/ombudsman.htm

 (800) 337-0429

 Ombudsman@frb.gov

The Ombudsman’s office facilitates the fair and timely resolution of 

complaints related to the Federal Reserve System’s regulatory activities. 

The Ombudsman serves as an independent, confidential resource for 

individuals and institutions that are affected by the Federal Reserve 

System’s regulatory and supervisory actions.
60 | FDIC | OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES

Federal Ombudsmen Directory

NATIONAL CREDIT UNION ADMINISTRATION (NCUA)

https://www.ncua.gov/about-ncua/leadership

 (703) 518-1175

 ombudsman@ncua.gov

NCUA’s Ombudsman reviews consumer complaints and recommends 

possible solutions. The issues generally result from process concerns. As 

a consumer, you may choose to bring your concern to the Ombudsman 

after attempting to obtain resolution from the NCUA Consumer 

Assistance Center.

OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC)

https://www.occ.gov/ See Dispute Resolution section

 (202) 649-6800

 OCCOmbudsman@occ.treas.gov

Fair, Accessible, Reasonable The Office of the Comptroller of the 

Currency (OCC) appeals process for national banks and federal savings 

associations (collectively, banks) provides an independent, fair, and 

binding means of resolving disputes arising during the supervisory 

process; helps ensure the most sound supervision decisions possible; 

and promotes open, continuous communication between banks and 

the OCC.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)

https://www.sec.gov/ombudsman

 (877) 732-2001

 Ombudsman@sec.gov

The SEC Ombudsman is a confidential, impartial, and independent 

resource who serves as a liaison to help individual investors —

sometimes referred to as retail investors or Main Street investors— 

resolve problems they may have with the SEC or with the self-regulatory 

organizations the SEC oversees. The SEC Ombudsman also reviews and 

recommends policies and procedures to encourage persons to present 

questions and feedback about the securities laws, and establishes 

safeguards to maintain the confidentiality of communications between 

Individuals and the SEC Ombudsman.
OFFICE OF THE OMBUDSMAN REPORT ON 2019 & 2020 ACTIVITIES | FDIC | 61

ABOUT THE COVER PHOTO

G.L. GIANNETTI STUDIOS

1416 M Street, N.W., Washington, D.C.

The renowned and award-winning sculptures of 

Gregory L. “George” Giannetti, grace many historic 

buildings in Washington, D.C. including the White 

House, the U.S. Capitol, the State Department, the 

Smithsonian Institution, and American Embassies 

throughout the world. As a resident of Washington 

and Maryland for more than forty years, Giannetti 

was considered the subject matter expert in 

designing Presidential Seals for inaugural stands. 

Respected for this unique expertise, Giannetti 

advised that the eagle on the Presidential Seal 

be changed to face right, rather than left. In 1945, 

President Harry Truman accepted this design change 

and the eagle was modified in an “about face” 

and displayed in this manner at the Washington 

Cathedral, the Marine Memorial, the State 

Department, and the Rayburn House Office Building. 

FDIC History

A special thank you to Robert “Bob” Giannetti and his family for sharing your Dad’s story, these historical photos and biography. 
“The Office of 

the Ombudsman 

is a vital arrow 

in the FDIC’s quiver.

Please continue to dedicate the 

time and resources needed to 

keep this channel alive and well.”

ANONYMOUS FEEDBACK FROM THE 

2019 CUSTOMER SATISFACTION SURVEY

FDIC’s Graphic Design and Printing Unit

PUBLICATION FDIC-005-2021