Modifications to Statement of Policy for Section 19 of the Federal Deposit Insurance Act

요약

The FDIC originally promulgated the Statement of Policy for Section 19 of the Federal Deposit Insurance Act (SOP) in December 1998. The FDIC, in 2007, issued a clarification to the SOP based on the 2006 amendment to Section 19 of the Federal Deposit Insurance Act, which addressed institution-affiliated parties (IAPs) participating in the affairs of Bank Holding Companies, or Savings and Loan Holding Companies. The FDIC, in 2011, clarified the SOP as to: (i) The applicability of section 19 on bank and thrift holding company institution-affiliated parties; (ii) the term "complete expungement;" and (iii) the factors for considering de minimis convictions. The FDIC is restating the full SOP, including previous changes, and modifying what the FDIC views as the definition of de minimis offenses.