Reference: FIL-26-2026
Official publication: Read the full FIL-26-2026 on the agency website
The Federal Deposit Insurance Corporation (FDIC) recently announced the publication of the Office of Ombudsman’s 2025 Annual Report. As a neutral and confidential resource established under the Riegle Community Development and Regulatory Improvement Act of 1994, the Office of Ombudsman (OO) plays a pivotal role in the tripartite relationship between the regulator, the regulated institutions, and the public. The 2025 report serves as both a statistical summary of the previous year’s grievances and a forward-looking indicator of supervisory friction. For financial institutions navigating an increasingly complex regulatory landscape, the trends identified in this report offer essential insights into the current state of examination quality, communication efficacy, and the mechanics of informal dispute resolution within the FDIC.
Executive Summary
- Volume Trends: The report details a continuing trend in institutional inquiries, particularly regarding the duration and transparency of the examination process.
- Neutrality and Confidentiality: The Office of Ombudsman reaffirmed its commitment to providing a safe harbor for institutions to voice concerns without fear of supervisory retaliation.
- Examination Disputes: A significant portion of the report focuses on disputes arising from CAMELS ratings, asset quality assessments, and management evaluations.
- Application Delays: The report highlights ongoing frustrations within the industry regarding the timelines for processing mergers, acquisitions, and change-in-control applications.
- Strategic Recommendations: The Ombudsman has provided several specific recommendations to the FDIC Board aimed at improving the consistency of regional office communications.
- Resolution Efficacy: The data suggests that informal intervention by the Ombudsman often leads to clarifications that preclude the need for formal, high-stakes appeals.
What the Regulator Issued
On the specified date of publication, the FDIC released the 2025 Annual Report of the Office of Ombudsman. This document is a statutory requirement and provides a comprehensive look at the activities of the Office over the preceding fiscal year. The report is intended to serve as a feedback loop for the FDIC Board of Directors, identifying systemic issues that may not be apparent through individual examination reports. The full report and the accompanying Financial Institution Letter (FIL) can be accessed directly through the official FDIC website at https://www.fdic.gov/news/financial-institution-letters/2026/fdics-office-ombudsman-publishes-2025-annual-report. The publication details the Office’s outreach efforts, the nature of the inquiries received, and the specific outcomes of Ombudsman interventions in supervisory disputes.
Who Is Impacted
The implications of the 2025 Annual Report extend across the entire spectrum of FDIC-supervised entities. Specifically, the following stakeholders should take note of the findings: Executive Management of insured depository institutions who are responsible for maintaining the regulatory relationship; Bank Counsel tasked with managing formal and informal appeals of material supervisory determinations; Compliance Officers who monitor the impact of supervisory feedback on institutional risk profiles; and Investors or Acquirers currently involved in pending applications where regulatory delays may be a factor. Furthermore, the report provides valuable benchmarking data for regional banks that may be experiencing friction with specific FDIC regional offices, allowing them to determine if their challenges are idiosyncratic or part of a broader systemic trend.
Key Dates and Deadlines
Not specified in the release. As this is an annual report reflecting on the previous year’s activities, there are no immediate filing deadlines or compliance dates triggered by its publication. However, institutions should view the release date as the beginning of a new cycle for reviewing internal protocols for Ombudsman engagement.
Practical Action Checklist
- Conduct a Retrospective Audit: Review all 2025 examination cycles to identify any unresolved friction points that mirror the trends cited in the Ombudsman report.
- Assess Dispute Resolution Protocols: Evaluate internal policies for escalating disagreements with examiners. Determine at what stage the Office of Ombudsman should be engaged versus pursuing a formal appeal through the Supervision Appeals Review Committee (SARC).
- Monitor Examination Timelines: Track the duration of recent examinations and compare them against the national and regional averages highlighted in the report to identify potential delays early.
- Update Board Reporting: Ensure the Board of Directors is briefed on the availability and function of the Ombudsman as a neutral arbiter, emphasizing the confidentiality protections afforded to the institution.
- Review Application Status: For institutions with pending applications, analyze the report’s sections on application processing to understand common causes for delay and prepare proactive responses.
- Analyze CAMELS Feedback: Pay close attention to the report’s commentary on asset quality and management ratings, as these are frequent areas of Ombudsman intervention.
- Evaluate Regional Variations: Determine if the institution’s primary regulator (regional office) is identified in the report as having specific communication or consistency challenges.
- Standardize Communication Records: Maintain meticulous records of all communications with examiners to support any future informal inquiries via the Ombudsman.
- Benchmark Informal Outcomes: Use the report’s data on successful informal resolutions to set realistic expectations for the outcome of Ombudsman mediation.
- Engage Regulatory Counsel: Consult with counsel to determine if a specific supervisory determination qualifies as a “material supervisory determination” eligible for Ombudsman review.
- Review the Ombudsman’s Charter: Ensure that the legal and compliance teams understand the specific limitations and powers of the Office to avoid over-reliance on the office for non-supervisory issues.
- Prepare for 2026 Examinations: Incorporate the lessons learned from the 2025 report into the institution’s preparation strategy for the upcoming supervisory cycle.
Open Questions / Watch Items
While the 2025 Annual Report provides significant clarity on past events, several questions remain for the upcoming year. First, it remains to be seen how the FDIC Board will implement the Ombudsman’s recommendations regarding regional consistency. Institutions should monitor for new Financial Institution Letters that might signal shifts in supervisory policy based on this feedback. Second, the effectiveness of the Ombudsman in resolving disputes related to emerging risks—such as third-party risk management and climate-related financial risks—is not yet fully documented in the 2025 data. Finally, the industry should watch for any changes in the volume of formal appeals; a decrease may indicate that the Ombudsman is successfully resolving issues informally, while an increase may suggest that supervisory stances are hardening despite the Office’s efforts.
My Law Tampa publishes this memorandum to provide regulatory updates and legal analysis for the banking and financial services community. We monitor the activities of the FDIC and other federal regulators to ensure that institutions have the information necessary to manage their regulatory relationships effectively.
This memorandum is provided for informational purposes only and does not constitute legal advice. No attorney-client relationship is formed by the publication or receipt of this information. Institutions should consult with their own legal counsel regarding specific supervisory issues or material determinations.
Source Materials
- Official publication: FIL-26-2026
- Regulator archive: FDIC memo archive
- Memo library: browse the full regulatory memo archive
- Related memo: FDIC Summary of Deposits Survey and Filing Instructions for June 30, 2026
- Related memo: FDIC Proposes Rigorous BSA and Sanctions Standards for Permitted Payment Stablecoin Issuers
- Related memo: Modernizing the CAMELS Framework: Analyzing the FDIC’s Proposed Revisions to the Uniform Financial Institutions Rating System
