To our clients and friends:

Brendan Clegg, Partner at Luse Gorman, recently authored an article for American Banker’s BankThink titled “Banks Deserve the Ability to Appeal Regulators’ Enforcement Actions.”

As the federal bank regulators reassess various aspects of the supervisory framework and revise their policies and procedures to improve efficiency, there is an opportunity to expand their appeals processes to allow banks a prompt, independent, and cost-effective avenue to challenge the bases for, and decisions around, enforcement actions.

This piece discusses the reasons why banks would benefit from the ability to use the agencies’ appeals process to contest the bases for recommended enforcement actions, and suggests now is the time to make this reform.

Luse Gorman regularly advises banks on supervisory issues and enforcement actions taken by federal and state bank agencies. If you have any questions related to these issues, please reach out to Brendan Clegg, at (202) 274-2034 or by email at bclegg@luselaw.com. To learn more about our firm and services, please visit our website.