Background Investigations

Appendix A: Appendix A: Management Review Guidelines

The OCC has developed these guidelines to assist national bank directors and organizing national bank directors (board of directors) in their selection of proposed management officials.

The selecting officials should:

  1. Require each proposed executive officer (candidate) to submit information requested in theInteragency Biographical and Financial Report, if necessary, to the board of directors for review.

  2. Perform a credit check of the candidate, identifying the credit bureaus or other sources used.

  3. Contact the candidate’s references and summarize by name the comments received.

  4. Contact the candidate’s previous employers and summarize by name and employer the nature of comments provided (for example, positive, negative, no comment).

  5. Prepare or obtain a summary of the candidate’s duties in previous positions and discuss how that experience relates to the job description under consideration. Discuss relevant information, such as:

    • Size and type of loan portfolio supervised, loss/earnings record, and amount of loan approval authority.

    • Personnel administration record, including the number and type of employees supervised and the candidate’s performance record.

    • Policy development and implementation experience.

    • Asset/liability management strategies employed.

    • Investment strategies employed.

    • Internal control, audit, and management information systems developed.

  6. Describe all terms of employment, including proposed salary, methods used to determine the amount of salary, employment contract, and other compensation.

  7. Describe the major duties and responsibilities of the position (if necessary).

  8. If applicable, evaluate and prepare documentation to support an exemption under the Depository Institution Management Interlocks Act (DIMIA).

  9. If OCC approval is required, submit the following information with the appropriate request:

    • Board’s written evaluation, reflecting its assessment of the proposed management official (results from steps 2 through 8).

    • Interagency Biographical and Financial Report (if necessary).

    • If applicable, request for DIMIA exemption.

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