Regulatory Alerts2008-02-29
Background Checks on Directors and Senior Management of FREs
The Office of the Superintendent of Financial Institutions (OSFI) requires federally regulated entities to establish and maintain written assessment policies evaluating the suitability and integrity of directors and senior management. These frameworks must mandate initial appointments and periodic reviews, typically within five years, that verify criminal records, professional qualifications, conflicts of interest, and civil proceedings through independent searches or attestations. OSFI expects senior management to approve these policies, document escalation procedures for adverse findings, and retain assessment records for supervisory examination while retaining legislative authority to remove individuals deemed unsuitable or lacking integrity.