Iowa Banking Law Blog

A heads up: Recent stories regarding FDIC rules for hiring and retention of employees
Sep. 11, 2012L. Allyn Dixon Jr., Iowa Banking Law Blog
Background checks

The past couple of weeks have seen an unusual amount of media focus on financial institution employee background checks and related dismissals. At least one dismissal has prompted a civil rights complaint. Not only should your institution be sure it is complying with Section 19 of the FDIC Act and the regulations and guidance associated with that part of the Act by regularly performing such checks, but that the implications of violations, which include fines of up to $1,000,000 a day, as well as the waiver process and de minimis exceptions are specific in nature.

You should understand that Section 19’s requirements are not the same as the more recent National Mortgage Lender licensing requirements, which, while similar in some respect to Section19’s prohibitions, differ in some material respects.

For more information about these compliance issues, contact Allyn Dixon at 515.246.4520 or at


share this page:
  • Facebook
  • LinkedIn
  • Twitter
  • Google Bookmarks
  • StumbleUpon
  • Digg
Categories: Allyn Dixon, Banking Law
Practice Area Categories: Banking Law

L. Allyn Dixon Jr.




Latest Articles

New “Know Your Vendor” Guidance from the OCC

In a recent Bulletin, the Office of the Comptroller of the Currency published new guidance […]

Delay Announced for Key Affordable Healthcare Act Provisions

Yesterday afternoon, the Treasury Department announced that employers with more than 50 full time equivalent […]

Against this background . . .

In recent months, we’ve noticed a substantial increase in the number of Section 19 waiver […]