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BOARD OF GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

WASHINGTON, D.C. 20551

DIVISION OF BANKING

SUPERVISION AND REGULATION

SR 15-8

June 25, 2015

TO THE OFFICER IN CHARGE OF SUPERVISION

 AT EACH FEDERAL RESERVE BANK

SUBJECT: Name Check Process for Domestic and International Applications

Applicability: This guidance applies to all financial institutions supervised by the Federal 

Reserve, including those with $10 billion or less in consolidated assets.

Introduction

As part of the Federal Reserve’s responsibilities as the primary federal banking regulator 

for bank holding companies, savings and loan holding companies, and state-chartered banks that 

are members of the Federal Reserve System (referred to as “supervised financial institutions” 1), 

the Federal Reserve reviews applications and notices (collectively, “applications”) that may 

include changes to the ownership and/or the composition of the board of directors or executive 

management of a supervised financial institution. For many of these applications, the Federal 

Reserve’s review includes an assessment of whether certain proposed shareholders and

policymakers have the competence, experience, integrity, character, and financial resources to 

effectively lead a supervised financial institution in a safe-and-sound manner.2

Under certain circumstances, the Federal Reserve also requests from other regulatory and 

investigative agencies background information about an individual or company involved in a 

proposal; this is commonly referred to as the “name check” process.

3

 This letter describes the 

Federal Reserve’s general name check process and the changes that are being implemented to 

 1

 Supervised financial institutions also include Edge act corporations and U.S. branches and agencies of foreign 

banking organizations.

2

 Various federal statutes require the Federal Reserve, in certain circumstances, to assess the competence, 

experience, integrity, and financial resources of individuals or companies proposing to become principal 

shareholders or policymakers of a supervised financial institution. See for example, 12 U.S.C. 1817(j) (changes in 

control of insured depository institutions); 12 U.S.C. 1831i (agency disapproval of directors and senior executive 

officers of insured depository institutions or depository institution holding companies); 12 U.S.C. 1842 (acquisitions 

of shares of banks or bank holding companies); and 12 U.S.C. 1467a (acquisition of shares of savings associations 

or savings and loan holding companies). In such situations, a fully completed Interagency Biographical and 

Financial Report (Form FR 2081c) must be provided. 

3

 For example, the Federal Reserve assesses information about the financial, employment, and criminal history of 

the individual or company subject to the name check.
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streamline and simplify the process and, thereby, help to reduce the burden associated with the 

application process overall, particularly for community banking organizations.

4

Previous Name Check Process

Under the previous process, name checks generally were conducted on all proposed 

officers and directors and/or new principal shareholders of a supervised financial institution 

involved in an application under consideration by the Federal Reserve.5 Exceptions were made 

for individuals considered “known to banking”6 and proposed outside directors with limited or 

no ownership interests (that is, less than five percent) in the supervised financial institution. 

Where the specific facts and circumstances warrant, name checks were conducted on an entire 

board or ownership group. For example, in proposals which involved numerous organizers (each 

with limited or no ownership in the relevant supervised financial institution) and no clear top 

policymakers, name checks generally were conducted for the entire group of organizers.

New Name Check Process

The Federal Reserve is implementing several changes to the name check process. The 

Federal Reserve generally will conduct name checks only on an individual that, upon 

consummation of an application, will become a principal shareholder or one of the top two 

policymakers of the supervised financial institution.7 In addition, the Federal Reserve will no 

longer take into consideration whether an individual is “known to banking” when determining 

whether a name check must be conducted. Rather, unless the facts and circumstances suggest 

otherwise, a completed name check will remain current for a period of five years, and individuals 

and companies with current name checks will generally not be rechecked, unless circumstances 

indicate to the Reserve Bank or Board staff that a name check is appropriate.

8

In addition to the above changes, the Federal Reserve will obtain credit bureau reports in 

certain limited situations to supplement and corroborate financial information provided in 

application filings or from other sources. The use of such “credit checks” will align our practice 

with that of other federal banking agencies. These credit checks will be conducted on an ad hoc 

basis when the facts and circumstance indicate that the information provided in the credit report 

 4

 Refer to SR letter 03-10, “Enhancements to the Name Check Process Related to Applications Reviewed by the 

Federal Reserve,” for guidance related to the finger printing process associated with name checks.

5

 The term “principal shareholder” is defined for banking organizations in Regulation Y (12 CFR 225.2(n)(2)) and 

for thrift organizations in Regulation LL (12 CFR 238.2(n)(2)) and means a shareholder that owns or controls 

10 percent or more of a class of voting securities of a supervised financial institution. “Acquisition of control” is 

described in the Change in Bank Control Act and Regulation Y (12 CFR 225.41).

6 Generally, an individual was considered “known to banking” if he or she had five years of relevant banking or 

thrift experience.

7 Where the proposed principal shareholder is a company, name checks generally will be conducted on the top two 

policymakers of the company. In the case of a group acting in concert, name checks generally would be initiated on 

all individual group members with five percent or greater individual ownership interests.

8

 The Federal Reserve will continue to evaluate the specific facts and circumstances surrounding a given application 

to determine the appropriateness of initiating name checks in situations other than those set forth in this letter. 

Further, name checks will continue to be required with respect to all notifications submitted pursuant to 

Regulation Y (12 CFR 225.72), unless the individual is considered exempt as a result of a recently completed name 

check, and no information exists indicating that a new name check should be initiated. 
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could be helpful to the Federal Reserve in its comprehensive assessment of individuals under 

review.

Questions with respect to policy matters discussed in this letter should be directed to the 

following staff in the Board’s Domestic/International Banking Acquisition and Activities

section: Susan Motyka, Manager, at (202) 452-5280; or Patrick Grant, Senior Supervisory 

Financial Analyst, at (202) 452-5214. Questions concerning the general process for conducting 

name checks can be directed to Susan Motyka; Patrick Grant; Katie Cox, Manager, at

(202) 452-2721; or Betsy Howes-Bean, Manager, at (202) 452-3096. In addition, institutions 

may send questions via the Board’s public website.9

Michael S. Gibson

Director

Cross References to:

• SR letter 03-10, “Enhancements to the Name Check Process Related to Applications 

Reviewed by the Federal Reserve”

 9 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.