Regulatory Alerts2018-07-01
Added · Updated
Antecedents (Q&A)
The document defines five categories of antecedents—criminal, financial, supervisory, tax compliance, and other—that impact the fit and proper assessment of policymakers in financial institutions. Financial institutions and policymakers are required to truthfully report these antecedents during initial assessments and immediately notify the regulator of any new occurrences. The regulator weighs reported antecedents against factors such as disclosure timing, gravity, and behavioral patterns, with only severe criminal convictions typically leading to an immediate negative propriety opinion. Informal supervisory measures imposed by the regulator or other authorities generally qualify as supervisory antecedents, though the qualification of an event as an antecedent itself is not subject to objection or appeal.