1. Background Checks - Banking The information presented by Inquirehire is not intended to be legal advice. Inquirehire recommends that you consult with legal counsel before making any decisions related to the information presented. Alan Kinsey, Vice President akinsey@inquirehire.com

2. Background Checks - Banking Agenda: 1.Section 19 of the FDIC Act 2.Key Requirements of Section 19 3.Background Check Techniques 4.Inquirehire Recommendations

3. Background Checks - Banking “Section 19 imposes a duty upon the insured institution to make a reasonable inquiry regarding an applicant's history, which consists of taking steps appropriate under the circumstances, consistent with applicable law, to avoid hiring or permitting participation in its affairs by a person who has a conviction or program entry for a covered offense.” https://www.fdic.gov/regulations/laws/rules/5000-1300.html Section 19 – Federal Deposition Insurance Act

4. Background Checks - Banking “It imposes a ten-year ban against the FDIC's consent for persons convicted of certain crimes enumerated in Title 18 of the United States Code, absent a motion by the FDIC and court approval.” https://www.fdic.gov/regulations/laws/rules/5000-1300.html Section 19 – Federal Deposition Insurance Act

5. Background Checks - Banking “The FDIC believes that at a minimum, each insured institution should establish a screening process that provides the insured institution with information concerning any convictions or program entry pertaining to a job applicant.” https://www.fdic.gov/regulations/laws/rules/5000-1300.html Section 19 – Federal Deposition Insurance Act

6. Background Checks - Banking Key Requirements for Bankers Conviction Records Search Program Entries Search 10 Year Search Scope

7. Background Checks - Banking In the US, Conviction Records are Stored in the Following Locations: Municipal and County Courthouses State Police Repositories FBI Database Federal District Courthouses

8. Background Checks - Banking Background Checks Techniques 1.Third Party Provider – jurisdictional searches using name matching techniques. 2.Statewide Check + FBI Database Search using fingerprint matching

9. Background Checks - Banking Third Party – Jurisdictional/Name Match Search Background Check Easier for candidates. Faster for the employer – generally complete in 24 to 72 business hours.

10. Background Checks - Banking FBI Fingerprint Background Check Inconvenient for the candidate Takes more time Data may not be fresh Includes non conviction information which could be illegal in some states, and considered discriminatory

11. Background Checks - Banking Program Entries 12 Federal Agency Restricted Lists – OFAC, HUD, FHFA are examples Lists contain persons who are banned from banking, either permanently or temporarily Free websites, but cumbersome to check and document

12. Background Checks - Banking Background Check Recommendations: Person Search/SSN Trace – identifies prior addresses and names used by the candidate. County Criminal Check – search all counties of residence for past 10 years. Nationwide Criminal Check – includes criminal records from all 50 states. Nationwide Sex Offender Check – includes all 50 state sex offender registries Federal Criminal Check – all federal district courts of residence for the past 10 years. Federal Agency Restricted Lists – all active lists

13. Background Checks - Banking Background Check Options: Employment Credit Report Driving Record Check Employment Verification Education Verification Professional Reference Check

14. For more information about employment screening for banking, contact Inquirehire. Phone: 800-494-5922 Email: solutionsupport@inquirehire.comsolutionsupport@inquirehire.com Alan Kinsey: akinsey@inquirehire.comakinsey@inquirehire.com