Officer/Director Background Checks

Sections in this Topic

Overview

As part of the applications process, officers and directors may be subject to background checks. The process, timing, and requirements for background checks vary among regulatory agencies. Banks should contact their primary regulator well in advance to understand the details of the process, since background checks may slow the application process.

Federal Reserve Requirements

The Federal Reserve background check requirement is a 60-day process, and advance submission is encouraged. Exemptions of officers and directors from background checks depend on previous positions held and length of service in banking. Biographical information, financial reports, and fingerprint cards should be submitted in a timely manner, as required. The local Reserve Bank can determine whether "live scan" is available for electronic submission of fingerprints.

Please be aware that the following issues may slow the background check process:

Submitting unreadable fingerprint cards (requires re-submission)
Submitting a middle initial versus the full middle name; specify if there is no middle name
Submitting incomplete data related to applicant business affiliation location, type of business, dates of affiliation, and position with applicant organization
Submitting incomplete financial statements/cash flow
Failing to fully disclosure prior legal issues