FAIR Exams Act — Independent Examination Review & Appeals
Current understanding
The FAIR Exams Act (introduced) would establish an Office of Independent Examination Review within the Federal Financial Institutions Examination Council (FFIEC) to hear appeals from financial institutions challenging findings in federal examination reports and to investigate examination-related complaints. The bill would create new procedural rights and statutory deadlines around the bank examination process, providing an independent adjudicative channel outside the primary federal banking regulators (OCC, FDIC, Federal Reserve, NCUA, CFPB). Status: introduced; no enacted changes yet.
Evidence log
- 2026-09-01 — Unsafe or Unsound Practices, Matters Requiring Attention: cross-connection with unsafe-or-unsound-practices-mra: Both address the framework and process for bank examinations and supervisory findings — the OCC/FDIC rule redefines the substantive standard and MRA process, while the FAIR Exams Act would create independent appeals for examination outcomes. (novelty: 3)
- 2026-05-13 — SMART Act of 2025: cross-connection with smart-act-small-depository-examinations: Both proposals adjust the federal bank/credit union examination regime — SMART Act narrows exam scope and cadence for small institutions, while FAIR Exams Act creates independent review/appeals of exam findings. (novelty: 2)