Background Investigations

Charters and Federal Branches or Agencies

The selection of competent senior executive officers reflects favorably upon applications. The OCC has developed a tool to assist banks in selecting management officials (see Appendix A -- Management Review Guidelines). Directors may use this tool as a guideline for obtaining relevant work experience about proposed management officials. When an organizing group for a new bank charter elects not to disclose the proposed CEO’s name at the time the charter application is filed, the proposed CEO still must complete and submit the Interagency Biographical and Financial Report. All questions should be answered, except those that disclose identifying information.

Identifying information generally is considered to include the person’s name, address, social security number, the name(s) of the financial institution(s) where the person is employed, other organizations where the person is affiliated as an officer, and information which, by its nature, would readily identify the proposed CEO.

When the name of a proposed CEO is treated as confidential in a filing or is not disclosed at the time of the filing, the background check is performed after the preliminary approval.

The CEO and all executive officer positions, in a new bank charter or federal branch or agency, must receive OCC approval prior to employment. Adverse information about the proposed CEO could reflect negatively on the filing and cause the OCC to reconsider its preliminary approval.

If a proposed officer requests that his/her present employer(s) not be contacted, the OCC will determine whether the information is needed and would be available through alternative sources. The OCC will notify the proposed officer in advance, if it needs to contact the current employer(s).

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