Joint Trades Comment on FDIC's Section 19 Proposed Regulations

Dear Mr. Sheesley:

The American Bankers Association and the Consumer Bankers Association
(the Associations) are pleased at the opportunity to comment on the proposed Federal Deposit
Insurance Corporation (FDIC) regulations, RIN 3064-AF92: Amending FDIC regulations to
conform with the Fair Hiring in Banking Act (FHBA) (the Proposed Regulations). Section 19 of
the Federal Deposit Insurance Act (Section 19) prohibits, without the prior written consent of the
FDIC, employment by a bank of any person who has been convicted of a crime involving
dishonesty or breach of trust or money laundering or who has agreed to enter into a pretrial
diversion or similar program in connection with the prosecution for one of these offenses, among
other prohibitions. The Proposed Regulations include potential amendments to the regulations
issued under Section 19 to conform the FDIC’s regulations with changes made in the FHBA. The
Proposed Regulations also include several other amendments not required by the FHBA,
including addressing the types of offenses covered by Section 19, the effect of the completion of
sentencing or pretrial-diversion program requirements in the context of Section 19, and the
FDIC's procedures for reviewing applications filed under Section 19.

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