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Federal Bank Regulatory Agencies Adopt Post-Termination Employment Restrictions for Their Senior Examiners

Effective December 17, 2005, the federal bank regulatory agencies finalized rules prohibiting their officers and employees from accepting compensation as an officer, an employee, a director or a consultant of a bank holding company or depository institution until one year after their service with the agency terminates, if the officer or employee served as a senior examiner of the institutions for at least two months during the last 12 months of that persons term of employment with the agency. These rules impose serious penalties on senior examiners who violate the prohibition. Accordingly, bank holding companies and depository institutions that are interested in hiring former officers and employees of their examining agencies should ensure that he or she is not subject to the prohibition.

For further information regarding these new rules, please call Andrew D. Bulgin at 410-576-4280 or your regular Gordon Feinblatt contact.