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Board Report: 2020-SR-B-003 March 9, 2020
Senior examiners at Reserve Banks are restricted from working for institutions they have supervised in the last year. The penalties for violating this restriction may include an industrywide prohibition for up to 5 years and a civil monetary penalty of up to $250,000. We evaluated Board and Reserve Bank controls for ensuring that this postemployment restriction is followed.
The Reserve Banks we evaluated each have policies and procedures for identifying and notifying employees subject to the postemployment restriction and for reviewing their work as appropriate. However, these Reserve Banks have taken different approaches to designating senior examiners, and the Board has not issued guidance clearly defining which employees should be considered senior examiners.
We recommend that the Board issue such guidance to promote consistency in applying postemployment restrictions to senior examiners.