For certain types of filings, the Federal Reserve is required to assess whether specific individuals have the competence, experience, integrity, character, and financial resources to effectively lead a supervised financial institution in a safe-and-sound manner. In these cases, individual(s) can provide a complete Interagency Biographical and Financial Report (IBFR), which can be found here, in order to furnish the information necessary for making the required determinations.
In some circumstances, the Federal Reserve also contacts other regulatory and law enforcement agencies for background information about an individual or company involved in a proposal; this is commonly referred to as the “name check” process. Name checks generally remain current for a period of five years, unless the facts and circumstances suggest otherwise. If you have completed a name check for the Federal Reserve in the last five years, please inform the Reserve Bank. Please note that the Federal Reserve cannot accept fingerprint cards completed for another agency, nor can it accept their namecheck in place of its own. Name checks of foreign nationals generally require extra time to complete.
The process for completing a name check involves the submission of fingerprints. The Federal Reserve will provide instructions by email directly to each individual that is required to submit fingerprints after receipt of the appropriate IBFR.
It is recommended filers contact their local Reserve Bank to discuss potential filings well in advance so they may advise of information requirements. IBFRs and fingerprint cards can be submitted in advance of final filing of an application or notice.
The name check process is described in SR 15-8 and the fingerprinting process is described in SR 20-20. Fingerprints should promptly be submitted according to the instructions provided. Failure to comply promptly could result in a delay in action on the related application.
Common IBFR Mistakes
In completing the IBFR, individuals should ensure that:
- the appropriate holding company or institution, or both, is specified on the first page, and all information is accurate and consistent;
- all questions have been answered, leave no question blank, use “N/A” or “None” to respond;
- all answers are complete with explanations for all responses with “Yes” responses;
- signatures have been provided; and
- financial schedules tie to the balance sheet and are mathematically correct.