Editor's Note: This article, authored by Justin B. Hosie, Eric L. Johnson and Laura J. Bacon previously appeared in Hudson Cook’s Insights Blog and is re-published here with permission. This article is provided for informational purposes and is not intended nor should it be taken as legal advice. The views and opinions expressed in this article are those of the authors in their individual capacity and do not reflect the official policy or position of the partners of Hudson Cook, LLP or clients they represent.

Bite 10: Director Chopra's Statement on Proposed Rule on Lifetime Bans

On October 24, 2023, CFPB Director Chopra, in his role as a member of the FDIC Board of Directors, released a statement on the new FDIC proposed rule that will implement new legislation to revise the current employment bans under the Federal Deposit Insurance Act ("FDIA"). The FDIA prohibits banks from employing people convicted of certain criminal offenses, and the new proposed rule will revise this prohibition by excluding certain offenses and reducing bans for individuals who were 21 years old or younger at the time of their offense. Director Chopra said that recruiting and retaining qualified employees is one of the biggest challenges facing banks today, and this proposal will create opportunities for more individuals to access employment opportunities and for banks to recruit qualified individuals. The CFPB director pointed out that while low-level employees can lose the ability to ever work in the industry after committing a crime, high-level executives repeatedly preside over financial crimes at banking institutions and must only pay a fine to continue their careers. He said that this proposed rule will help to correct that imbalance.

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