OCC Revises “Background Investigations” Booklet

The Office of the Comptroller of the Currency (“OCC”) made technical changes to the “Background Investigations” booklet of the Comptroller’s Licensing Manual. The booklet was substantively revised in November 2017.

The booklet outlines requirements for banks (i) to notify the OCC when there is a change of directors or senior executive officers, and (ii) to submit documents required by the OCC to review the background of proposed directors and executive officers. The booklet also describes prerequisites for exceptions and waiving the submission of required documents.

Lofchie Comment: Firms not regulated by the OCC may find the process outlined by the OCC useful in reviewing their own procedures for conducting background checks.

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