FDIC Office of the Ombudsman 2025 Annual Report

OFFICE OF THE OMBUDSMAN 2025 ANNUAL REPORT

WAYS WE HELP DIRECTOR’S MESSAGE When I stepped into the role of FDIC Ombudsman last fall, I brought more than three decades of experience at this agency – 24 years in bank supervision and 11 years as a Regional Ombudsman. Throughout that time, one simple yet important principle has stood out: bankers want supervision that is fair, transparent, and consistent. As the needs of bankers have evolved, so has the work of my office. Within our statutory framework, the Office of the Ombudsman is taking a more active role when supervision does not seem clear or easy to navigate. If an explanation is confusing, if expectations appear inconsistent, or if a process is not functioning as it should, we will stay engaged until a fair and well-understood resolution is reached. In some situations, that means helping a banker think through an issue; in others, it means ensuring all parties come together so the facts and decision points are fully understood. If something does not seem fair or transparent, I encourage you to contact us early – before supervisory decisions are finalized. We are here to make sure you are heard and to provide the support you need when it matters most. As you read through this report, you will see more about how our role continues to evolve and the ways we are strengthening our ability to assist you. Sincerely, DAN MARCOTTE Director 877-275-3342 Ombudsman@FDIC.gov Strengthen Trust – We promote transparency and accountability so institutions and regulators can work from the same facts and understanding. Clarify Expectations – When guidance or examination feedback is not clear, we help parse the issues and align on what is expected. Resolve Friction – If supervision appears to be inconsistent or unfair, we convene the right people and remain engaged until the issue is resolved. Identify Trends – We identify emerging issues and share insights that inform process improvements. 2

3 CORE OF WHO WE ARE Independent and Impartial Perspective • A neutral voice outside the supervisory chain that helps clarify issues without bias. • Balanced understanding of examination and application challenges to help resolve problems more quickly. Confidentiality and Voice • A safe place to raise examination or application concerns candidly, without risk of repercussions. • Open dialogue that leads to clearer problem definition and better outcomes. Informal, Fast, and Effective Help • Practical solutions delivered through direct conversations. • Early resolution that prevents misunderstandings from becoming formal disputes. Fairness, Consistency, and Clear Communication • Confidence that supervisory expectations are applied fairly across regions and examination teams. • Improved communication when examiner findings seem unclear or inconsistent. Integrity, Accountability, and Support • Guidance from seasoned professionals who understand complex supervisory issues. • Transparent follow through and correction of errors when they occur. OUR VALUES IN ACTION We envision a regulatory environment where fairness, transparency, and respect are foundational and financial institutions are empowered to serve their communities fairly and meet the needs of their customers in a safe and sound manner. In this environment, supervisory processes are applied equitably; bankers are heard without fear of reprisal; and both institutions and regulators contribute to a shared culture of trust, accountability, and continuous improvement. VISION Fairness Transparency Respect Our mission is to enhance public confidence in the FDIC by helping to ensure the fair and consistent application of FDIC rules and regulations. We do this as an independent, impartial, and confidential resource, promoting transparency and accountability through practical, collaborative problem solving with stakeholders. MISSION Bank FDIC Ombudsman

4 HELP WHEN IT MATTERS MOST When examination challenges surface, our office gives bankers a safe, neutral place to get clarity quickly. Because we operate outside the supervisory chain, you gain an independent perspective that helps untangle issues before they harden or become more complicated. You can speak openly – confidentiality is safeguarded. Our process is informal, efficient, and focused on practical solutions. We help ensure fairness and regulatory consistency across examination teams and regions, which helps to reduce friction and improve communication when decisions seem unclear. Behind every interaction with our office is a skilled and impartial team member who is committed to fair process and follow-through. We help ensure the supervisory process works as intended, so your institution can focus on serving customers, supporting communities, and operating safely and soundly. When concerns arise, reaching out is simple, risk-free, and often a fast path to resolution. We are here to help you be heard and help you move forward with confidence. We are here when “ you need us.” WHEN TO CALL THE OMBUDSMAN CALL EARLY We can help most when analysis is still in motion and while findings are preliminary – before final decisions are made. ❒ An examination or application finding or process does not seem clear or consistent. ❒ Concerns arise about fairness or due process in an evolving supervisory issue. ❒ Assistance is needed getting key stakeholders to align on facts and expectations. ❒ A confidential sounding board is desired before regulatory decisions are finalized. ❒ An issue is stalled and you need a neutral facilitator to move it forward.

5 TRUST OUR PROCESS START BY RAISING AN ISSUE You contact us with a concern or question. We protect your identity. LISTEN & CLARIFY We listen to your concerns and identify what seems unclear, inconsistent, or unfair. We review issues, timelines, and decision points. MAP THE FACTS Pending your authorization, we convene the right participants to ensure a shared understanding. ENGAGE STAKEHOLDERS We provide you with options to achieve a fair, transparent, and consistent outcome. FACILITATE RESOLUTION We confirm next steps and capture insights learned for process improvement. CLOSE THE LOOP & SHARE LESSONS • Prevents avoidable escalations by resolving misunderstandings at the lowest possible level. • Improves outcomes when facts and expectations are aligned. • Reduces burden by avoiding misdirection of effort. • Builds trust by creating early transparency and ensuring everyone is working from the same set of facts. WHY EARLY MATTERS We promote fair “supervisory engagement.”

6 SUCCESS STORIES CALMING AN OVERWHELMED BANK OFFICER A newly hired senior officer felt rattled by what they believed was overly harsh preliminary examination feedback and decided to call their regional ombudsman. We listened, explained examination procedures, and offered low pressure ways for the officer to ask clarifying questions. The officer followed up confidently with the examination team, leading to an appropriate and mutually understood examination finding. The officer sent the Ombudsman Director an email with the following message: “Talking with my regional ombudsman really helped me understand what the examiner was trying to do, and it gave me the confidence to ask the questions I needed. When I followed up, the conversation went smoothly and the final finding made a lot more sense.” ADDRESSING EXAMINER BEHAVIOR A bank CEO contacted their regional ombudsman with concerns about an examiner’s confrontational tone that was disrupting the working dynamic of the examination. The CEO was not sure how to address the sensitive issue without escalating tension. The regional ombudsman presented various options for addressing the concern. The CEO waived confidentiality and asked the regional ombudsman to discuss the situation with the examiner’s supervisor. After a productive discussion between the regional ombudsman and the supervisor, the supervisor quickly engaged the banker, assured the CEO the issue would be handled, and followed up to close the loop. The banker phoned the regional ombudsman stating their genuine happiness with the outcome and how smoothly everything was addressed. They also said the regional ombudsman took a genuine interest in the situation, and that their diligent, caring guidance made all the difference. CLARIFYING A RUMORED DOWNGRADE Worried by informal examiner comments about a possible downgrade and unsure how to address this issue with the examination team, a banker reached out to us. We helped separate fear from fact, explained how proposed ratings are developed, and emphasized that constructive dialogue between the bank staff and examiners can help examiners refine or reconsider early impressions. Reassured, the banker sought clarification from the examiner-in-charge (EIC), and the examination concluded without a downgrade. A few days later, the banker sent a quick note to the regional ombudsman saying, “Thank you again for taking the time to talk with me the other day. Your explanation of how preliminary comments fit into the examination process, and your reassurance about asking clarifying questions, really helped me approach the situation with confidence. I spoke with the EIC, and the conversation was productive. I appreciate your support and perspective.”

7 SUCCESS STORIES (CONT’D) UNBLOCKING A STALLED APPLICATION REVIEW A bank’s application had been with the FDIC for several weeks, but the institution had received no updates on potential issues or a timeline for completion. Unsure how to move the process forward, the banker contacted their regional ombudsman. We identified the cause of the delay and facilitated more direct communication between the banker and the case manager. The application review progressed promptly, giving the bank a clear, predictable path to completion. After the application was approved, the regional ombudsman received a short email from the banker, thanking them for getting the process back on track. RESOLVING CONFUSION OVER CHANGING EXPECTATIONS During a routine examination, a banker became concerned when bank practices previously viewed as acceptable were now being cited as a regulatory issue. The banker contacted his regional ombudsman, who helped him understand potential situations in which unchanged practices might later be criticized and assisted him in formulating questions to ask the EIC. Through a productive conversation between the banker and EIC, the banker gained a clearer understanding that, although the bank’s practices had not changed, the rapid growth of the portfolio and evolving risks formed the basis for the regulatory concern. With alignment restored, the banker informed the regional ombudsman that he now understood the criticism and had a constructive conversation with the EIC about possible actions the bank could take to address supervisory concerns. We listen. We clarify. “ We convene. We resolve.”

8 AUTHORIZATION & FAQs REMEMBER Our office was created as part of the Riegle Community Development and Regulatory Improvement Act of 1994 (Riegle Act), in response to the industry’s feedback to Congress in the early 1990s. The Riegle Act required federal banking agencies, such as the FDIC, to appoint an independent Ombudsman to act as a neutral liaison between the agency and anyone affected by its activities. Our office handles complaints and helps resolve disputes arising from the FDIC’s regulatory, resolution, receivership, or asset disposition activities. Our goal is to efficiently and effectively resolve issues at the lowest possible level and help complainants find solutions that can avoid the potential time and cost associated with the appeals process, litigation, or administrative adjudication. DID YOU KNOW? BANKER FAQs • Talk with the Ombudsman We help keep supervision fair, transparent, and consistent. • Bring Us in Early Confidential guidance before decisions are final. When should bankers contact the Ombudsman? Early – before decisions are finalized. That is when we can help the most. Will the Ombudsman keep my identity confidential? Yes. We protect the identity of individuals and institutions who contact us. Is the Ombudsman part of the supervisory team? No. We are independent and impartial. Our role is to promote fairness, consistency, and clear communication. What kinds of issues does the Ombudsman handle? Safety and soundness, consumer protection, and bank resolution matters where fairness, clarity, or consistency are in question. Can the Ombudsman change a supervisory decision? No. We do not direct outcomes. Instead, we help clarify facts, align expectations, and facilitate fair resolution. That process may influence decision changes if those decisions were based on misunderstandings or inconsistencies. 114 BANKER CASES RECEIVED IN 2025

9 OTHER Activities To ensure confidentiality of bank responses, promote candid feedback, and encourage increased response rates, our office continues to administer the Post-Examination Survey (Survey). We report anonymized results and comments to the directors of the Division of Risk Management Supervision and the Division of Depositor and Consumer Protection. If you want to discuss your examination experience or survey responses in more detail, you can ask your regional ombudsman to contact you by completing the last page of the Survey and selecting “Yes”. In 2025, regional ombudsmen responded to 38 follow-up requests from bankers. In 2025, 54 percent of examined banks responded to the Survey. When you receive your next Survey, please make sure you respond. The FDIC uses your candid and meaningful feedback to improve the examination and supervision process. POST-EXAMINATION SURVEY The Ombudsman also serves as the FDIC’s Freedom of Information Act (FOIA) Public Liaison. During 2025, our office received 46 requests for assistance. We provided status updates, helped reduce fulfillment delays, and answered general questions about the FOIA process. We also provided feedback to FDIC FOIA staff, shared trends, and suggested process improvements that helped reduce the overall number of FOIA￾related concerns throughout the year. FOIA PUBLIC LIAISON Confidential. Independent. Impartial.

HOW YOU CAN RESPOND Office of the Ombudsman E-2048 3501 Fairfax Drive Arlington, VA 22226 1-(877)-275-3342 Ombudsman@fdic.gov Online Form SAN FRANCISCO DALLAS KANSAS CITY ATLANTA CHICAGO NEW YORK REGIONS SHARE YOUR FEEDBACK ABOUT THIS REPORT ACCESS THE ANONYMOUS ONLINE FORM HELP IMPROVE FDIC PROCESS Your thoughts and opinions about supervisory or resolution processes are important to FDIC leadership. Please CONTACT THE OMBUDSMAN to share your comments, suggestions, or observations. If something does not seem “ clear or fair, call us early.”