FDIC Proposes Revised Statement Of Policy

On January 8, 2018, the Federal Deposit Insurance Corporation (FDIC) proposed a revised Statement of Policy (SOP) for Section 19 of the Federal Deposit Insurance Act (FDI Act).¹ Section 19 prohibits, without the prior written consent of the FDIC, any person from participating in banking who has been convicted of a crime of dishonesty or breach of trust or money laundering, or who has entered a pretrial diversion or similar program (program entry) in connection with the prosecution for such an offense. It also requires insured institutions to screen job applicants to avoid hiring or permitting participation in the affairs of the institution by persons who have covered criminal histories. Among other substantive and technical changes, the proposed SOP seeks to reduce regulatory burden by decreasing the number of covered offenses that will trigger an application, such as offenses involving multiple "bad" checks amounting to less than $1,000 and minor drug