Appendix 1 of this report includes additional details on our objective, scope, and methodology.BackgroundDuring the recent financial crisis, DRR hired a significant number of temporary employees to meet workforce needs. We assessed the FDIC’s consideration of veterans in the hiring process for the 13 announcements that we reviewed as shown in Table 1. b Recommendations will be closed when the OIG confirms that corrective actions have been completed and are responsive. DRR Vacancy Announcements Analyzed by the OIG 3. As such, all DRR subject-matter experts have been using the same review sheets to better ensure consistent reviews and DOA concurrence; and- DOA began following its Quality Review Procedures by having DOA staff perform initial quality reviews and then forward applicants deemed qualified to subject-matter experts for review.DOA had provided limited training to subject matter experts regarding the application review process, which included notifying them of the requirement to document and identify information in applications to support their conclusions. All applicants on the certificate are deemed to be minimally qualified for the position. 2016-036), dated May 24, 2017. The Schedule A announcements were only open to current FDIC employees and required the FDIC to comply with veterans’ preference provisions.Applicants who met the required qualifications were placed on a certificate of eligibles (certificate). DRR documented its decision to not fill the vacancy and obtained management approval as required by FDIC policy. If you need a reasonable accommodation for any part of the application and hiring process, please contact the FDIC's Reasonable Accommodation Coordinator at (703) 562-2096 or RACoordinator@FDIC.gov . [End of Table 3][End of Appendix 2]Appendix 3Allegations that Were Not SubstantiatedAs discussed in the report, we were not able to substantiate allegations that qualification factors in certain DRR vacancy announcements were too restrictive or DRR attempted to exclude qualified veterans from certificates. FDIC Topics Replies Views Last Post FDIC’s June Hiring Event canceled NoodleCounter, 3/16/2021 4:03:10 PM(UTC) 2 228 NoodleCounter 3/17/2021 6:59:07 AM(UTC) Reference Called - Have Not Had Interview Fed3117, 9/7/2020 11:04:42 AM(UTC) 5 2,143 teeeeej Please note that all systems within the FDIC’s Personnel Security process are designed to store and transmit every portion of your data securely. Visit the But no subject causes more dread and anxiety than salary negotiations. Nevertheless, we concluded that DOA should provide guidance to divisions and offices on this matter to ensure that qualification factors are not overly restrictive. See questions about. Such guidance would provide greater assurance that vacancy announcements are perceived as fair and limit the risk of employee concerns.RecommendationWe recommend that the Director, DOA:5. The amended Schedule A hiring authority required the FDIC to comply with veterans’ preference provisions in 5 C.F.R. - United States Code[End of Appendix 5]Appendix 6Corporation Comments[FDIC letterhead, FDIC logo, Federal Deposit Insurance Corporation, Division of Administration, 3501 Fairfax Dr., Arlington, VA, 22226]DATE: July 6, 2017 MEMORANDUM TO: E. Marshall Gentry, Assistant Inspector General for Program Audits and Evaluations FROM: Arleas Upton Kea, Director, Division of AdministrationBret D. Edwards, Director Division of Resolutions and Receiverships SUBJECT: Management Response to the OIG Draft Evaluation Report Entitled, FDIC’s Process for Filling Certain DRR Time-Limited Positions (Assignment No. Most of us aren’t used to talking about money, let alone negotiating. Part 302. (3) Management agrees to the OIG monetary benefits, or a different amount, or no ($0) amount. The scope of our evaluation focused on 13 DRR vacancy announcements that were the subject of the complaints.2 The open period for the 13 announcements spanned from June 4, 2015 through November 20, 2015. … section 2301(b) – Merit System Principles.o Title 5 U.S.C. The day of your interview you will call in and be placed on a call with 2+ FDIC Employees. equal opportunity page Supporting your physical, financial and emotional wellness. The sequential involvement of DOA human resources officials followed by a separate subject-matter expert review of applicant qualifications provides an important segregation of duties in the application review process.- Subject-Matter Expert Review Sheet Criteria Were Not Always Consistent with Vacancy Announcement Requirements. Benefits . The Federal Deposit Insurance Corporation (FDIC) recently published its final rule on modifications to the Statement of Policy (SOP) for Section 19 of the Federal Deposit Insurance Act, 12 U.S.C. The hiring process is a joint After updating these materials, DOA plans to provide additional training to DRR and other FDIC Divisions and Offices. If you need a reasonable accommodation for any part of the application and hiring process, please contact the FDIC's Reasonable Accommodation Coordinator at (703) 562-2096 or RACoordinator@FDIC.gov. The FDIC performs a public trust background check on you (after you accept your tentative offer) and before they give you the final offer letter. created by the Congress to maintain stability and public confidence in the 2 Coordinator at (703) 562-2096 or These actions will ensure only duties reflected in position descriptions are used in specialized experience statements in vacancy announcements. A DRR resource management official informed a DRR executive of this situation and identified another individual who could have served as the selecting official for the subject vacancy announcement. Browse our Hiring decisions are made jointly by the agency’s Division of Administration and the Division of Resolutions and Receiverships, following a set of guidelines that govern the selection process. However, to expedite the hiring process, DRR subject-matter experts in the Dallas office conducted qualification reviews of all applicants associated with the 10 Dallas announcements before DOA human resources officials determined which applicants were eligible and met minimum qualification requirements. Watch later. Second, the FDIC has made several changes that narrow the scope of crimes subject to Section 19 and the circumstances under which the FDIC’s written consent is required for a financial institution to hire individuals with minor criminal offenses, thereby enabling more individuals to work for FDIC member banks without having to go through the Section 19 application process. DRR achieved its workforce reduction primarily through the scheduled expiration of temporary appointments.In its efforts to retain a limited number of non-permanent employees, DRR announced certain new, time-limited positions using an amended Excepted Service Schedule A Hiring Authority granted by the Office of Personnel Management (OPM). We also identified process-related matters, which could have presented applicants with the perception that DOA was not leading or sufficiently engaged in the candidate review process and/or posed risks that applicants could be erroneously included or excluded from certificates. Determinations on requests for reasonable accommodation will be made on a case-by-case basis. These weaknesses related to DOA and DRR’s application review process and the use of qualification factors in certain vacancy announcements that were not reflected in position descriptions.We found that certain qualification factors were narrowly written. recommendations or FDIC officials who consider prohibited Further, FDIC takes seriously its commitment to carrying out hiring processes in a fair and equitable manner. Using qualification factors that are grounded in position descriptions helps ensure that applicants are judged on factors that are fundamental to the position being filled and consistency in candidate evaluation and selection decisions; in addition, it protects the agency from criticisms that selection criteria were biased.Some Qualification Factors Were Narrowly Written. changes for banks, and get the details on upcoming DOA plans to review the 2017 case files to ensure items such as specialized experience statements; position duties; and knowledge, skills, and abilities in vacancy announcements align with the official position descriptions. The FDIC provides reasonable accommodations to applicants with However, if the FDIC does not create a pool, or the pool is not adequately staffed due to hiring challenges, the FDIC may be faced with the rare event where a panel may be reduced to an even number of members (for example, due to a conflict of interest, illness or death of a member). What questions did they ask during your interview at FDIC? [End of Executive Summary]Table of ContentsBackground Evaluation Results Application Review Process Needs Improvement Recommendations 1-3 Qualification Factors Were Not Consistently Reflected in Position DescriptionsRecommendation 4 Some Qualification Factors Were Narrowly Written Recommendation 5 DRR Selected Veterans for Some Positions and Documented Hiring DecisionsConclusionCorporation Comments and OIG EvaluationAppendices1. Notwithstanding, as discussed later, we concluded that additional training for subject-matter experts was warranted.Evaluation ResultsWe substantiated aspects of the OIG hotline allegations and identified weaknesses in the FDIC’s process for filling certain time-limited positions. Interview. City National Bank. The FDIC will make determinations on requests for reasonable accommodation on a case-by-case basis. : 1; Corrective Action: Taken or Planned: DOA plans to update its Quality Review Procedures and communicate requirements to headquarters and regional human resources personnel and clients. FDIC Hiring Process and Controls to Ensure Fair Outcomes. FDIC’s Process for Filling Certain DRR Time-Limited Positions Report No. profiles, working papers, and state banking performance manages receiverships. In its simplest form, a position description indicates the work to be performed by the position. 1 Section 19 prohibits, without the prior written consent of the FDIC, a person convicted of any criminal offense involving … independent agency created by the Congress to maintain Really! For two of the 83 subject-matter expert reviews, there was no evidence of DOA concurrence, as required by the Quality Review Procedures. [End if Table 4][End of Appendix 3]Appendix 4Glossary of TermsCertificate of Eligibles (Certificate) - A list of the individuals meeting the announcement’s required qualifications and veterans’ preference requirements. Additionally, all 48 individuals were listed on the certificate corresponding to the job for which they were hired.Row 5; Unsubstantiated Allegation: An FDIC employee left the FDIC and was then rehired in contravention of OPM or FDIC rules. The interview was with 3 hiring managers and consisted of 4 behavioral questions with no feedback given. The FDIC may request an Learn more about disability employment and reasonable accommodations or how to contact an agency. The report identifies five recommendations for improvements to further strengthen process controls. trust and confidence in our nation's financial system, the FDIC These regulations are laid out in Section 19 of the Federal Deposit Insurance Act. The DRR resource management official informed us that he/she was not aware that the conflict went unresolved until after the announcement was closed. ; Explanation: The oath consisted of a one page document encouraging DRR employees to be mission driven, trustworthy, accountable and supportive; create a fun and enjoyable work environment; and address conflict with respect and maturity. Candidates must meet suitability requirements for federal Transition Assistance Plan (CTAP/ICTAP), People With Disabilities Employment Information, Equal Employment Opportunity Rights & Protection, FDIC Conditions of Employment & Security Process. Applicants must … An employee at FDIC is fully vested. In making this determination, we considered general language in the position descriptions that correlated to specific requirements in qualification factors as opposed to looking for verbatim or exact language. For the three headquarters announcements, DOA performed its eligibility and qualification review before the DRR subject-matter expert qualification review, consistent with the Quality Review Procedures. In most instances, documentation indicated that the veterans did not meet qualification factors, some of which were narrowly written.We also reviewed a sample of applicants selected for positions and found support in their applications indicating they met the qualification factors.ConclusionWe identified weaknesses in the FDIC’s process for filling certain time-limited positions, which could have contributed to perceptions that DRR’s selection process was unfair. and employment eligibility for anyone hired to work in the whistleblower retaliation protection page to learn more. * Applicants had to be current FDIC employees and meet experience equivalency requirements to be considered eligible. : 3; Corrective Action: Taken or Planned: After updating the Quality Review Procedures in response to recommendation 1, DOA plans to (1) hold meetings and discussions with headquarters and regional human resources staffing specialists, and (2) provide additional information and guidance to clients to ensure a thorough understanding of key requirements and functions. Estimated Completion Date: April 16, 2018Recommendation 4: The OIG recommends that the Director, DOA establish controls to ensure that qualification factors in vacancy announcements reflect job duties in the related position descriptions and incorporate additional procedures to this effect, if warranted.Management Response: DOA concurs with this recommendation.Corrective Action: DOA Staffing Specialists will further ensure that qualification factors used in vacancy announcements are reflected in the job responsibilities and duties of the applicable position description through the issuance and communication of the updated SOP referenced in our response to Recommendations 1. Subject-Matter Experts Reviewed Applications before DOA’s Initial Quality Review. However, based on our evaluation work, we were not able to substantiate allegations that qualification factors were too restrictive because there was an absence of sufficient criteria for doing so. Further, applicable requirements and guidance will be communicated to clients. Other allegations that we were not able to substantiate are in Table 4 below.Table 4: Allegations that Were Not SubstantiatedRow 1; Unsubstantiated Allegation: Thirty-five DRR employees; were not qualified for their positions, partly based on information in their LinkedIn profiles. To accomplish our objective, we focused on FDIC processes and controls for filling selected timelimited positions. For any part of the remaining hiring process, applicants should contact the hiring agency directly. I interviewed at FDIC (Washington, DC) in Jan 2020. For any part of the remaining hiring process, applicants should contact the hiring agency directly. formal offer of employment, as required by law (12 CFR Part It’s important that all job applicants The process took 2 days. More costly regulations (e.g., loans, CFPB, OCC), including 6. Benefits Interviews CEO Hiring Process Salaries Working Culture Working Environment Working Hours. As a result, only a limited number of DRR temporary employees were selected for new time-limited positions within DRR. Then there was a vetting process where they really do check out and confirm EVERYTHING. Estimated Completion Date: December 1, 2017Recommendation 3: The OIG recommends that the Director, DOA ensure that human resources personnel understand their role and the key functions they should perform in reviewing applications for vacancy announcements.Management Response: DOA concurs with this recommendation.Corrective Action: Upon completion of the updated SOP referenced in our response to Recommendation 1, specific meetings/discussions will be held with Headquarters and Regional HR Staffing Specialists to review the SOP and to ensure that all HR Staffing Specialists understand the key functions they are required to perform when reviewing applications for vacancy announcements. We also reviewed some applications that came to our attention outside our sample of 13 announcements. Apply. Answered August 8, 2019. The SOP will be completed by December 1, 2017. factor. : 4; Corrective Action: Taken or Planned: DOA plans to (1) send an email to DOA staffing specialists instructing them to not include anything in a vacancy announcement that is not clearly demonstrated in a position description through established duties, knowledge, skills, and abilities; and (2) communicate applicable requirements and guidance to clients. Monetary benefits are considered resolved as long as management provides an amount. In comparison, an average of 21 percent of the applicants were included in a certificate for the eight announcements with qualification factors that we determined were not so specific.The FDIC follows the Merit System Principles pursuant to Title 5 U.S.C. A DRR official encouraged DRR employees to embrace the oath and several DRR staff members voluntarily wrote their names on it. No. These weaknesses were related to potential conflicts of interest, maintaining confidentiality, ensuring adequate segregation of duties between DOA and DRR personnel, and non-compliance with DOA’s procedures for reviewing vacancy announcements.For example, we identified one instance where an applicant was also a selecting official and another instance where an applicant was also a subject-matter expert responsible for referring applications for selection. Objective, Scope, and Methodology 2. This employee was properly reinstated at the FDIC according to supporting documentation we reviewed.Row 6; Unsubstantiated Allegation: DRR did not allow applicants extra time to provide missing documentation supporting their job applications, in contravention of the Collective Bargaining Agreement between the FDIC and National Treasury Employees’ Union. In all 39 instances where a veteran was not qualified, we found explanations in the FDIC’s hiring system regarding why the veterans did not make a certificate. DOA HRB will issue its Audit Findings Report in April 2018.Estimated Completion Date: The SOP will be completed by December 1, 2017. Failing to obtain the FDIC's permission to hire such an individual can result in penalties of up to $1 million per day for the duration of the violation, or imprisonment for up to five years, or both. Clear. The initial subject-matter expert stated he/she was unaware that he/she had applied for the position because he/she applied for several DRR positions. “The hiring process felt very personalized because there were always people at Associated guiding me and quickly answering my questions, which made me feel welcomed before I was even hired.” - Andy “Associated Bank provides an opportunity for everyone to grow. We did not test this allegation.Source: OIG-compiled based on hotline allegations and related research. Qualification Factors in Vacancy Announcement that Were Narrowly Written: NoneSource: OIG-generated based on analysis of vacancy announcements and position descriptions. ; Explanation: The subject employee was a temporary employee who left the FDIC before the employee’s term expired. DRR was not required to allow applicants additional time, after a Schedule A job vacancy closed, to submit required supporting documentation. EVAL-17-006July 2017Executive SummaryFDIC’s Process for Filling Certain DRR Time-Limited PositionsWhy We Did the EvaluationThe Federal Government’s Merit System Principles provide that a fundamental tenet of the federal civil service is that hiring decisions should consider qualified individuals based on merit and ability, after fair and open competition. I forget how any pages, but it's VERY thorough. The hiring process is a joint responsibility between DOA human resources personnel and DRR program officials, and both divisions need to ensure the hiring process is fair, follows FDIC policies, and helps defend against complaints or criticisms.We made five recommendations to DOA to strengthen controls surrounding the FDIC’s application review process, better ensure subject matter experts comply with FDIC procedures for reviewing vacancy announcements, and ensure qualification factors in vacancy announcements are reflected in position descriptions and are not too restrictive. Part 302.Footnote 3: Excepted Service Schedule A Hiring Authority allows federal agencies to fill special jobs or any job in unusual or special circumstances. The Policy and Compliance Team will again conduct an audit of the DOA Staffing Operations Teams in February, 2018 and will review 2017 case files to ensure compliance with the procedures for conducting Quality Review of Applicants to Vacancy Announcements is being adhered to. Clarifying the process for job applicants on the FDIC website and on waiver applications; Requiring financial institutions to provide notice to applicants of the individual Section 19 waiver application process if an institution fails to apply for a waiver on the applicant’s behalf, and to make waiver forms easily available to applicants; and No. Of these 48 individuals, 31 did not previously report to any of the FDIC’s 3 TSOs and 8, 6, and 4 employees reported to the East Coast, West Coast, and Midwest TSOs, respectively. 1) A HUGE application. The workshop addressed competitive and excepted service and veterans’ preference, among other topics. DRR management informed us that they determined that the position would not support at least 2 years of work and therefore addressed the position with an expression of interest filled by several DRR staff on a rotating basis. The hiring process is a joint responsibility between Division of Administration (DOA) human resources personnel and DRR subject-matter experts. Implement additional controls to better ensure compliance with the Quality Review Procedures.2. DOA HRB will issue its Audit Findings Report in April 2018.Estimated Completion Date: The Assistant Director, Service Center will send the aforementioned email by close of business, July 14, 2017. Nevertheless, we reviewed a sample of 10 applications pertaining to three vacancy announcements from our sample (5 veterans and 5 non-veterans). As noted in the Figure on page 3, DOA should indicate its concurrence or non-concurrence with subject-matter expert qualification decisions. Qualification Factors in Vacancy Announcement that Were Narrowly Written: NoneRow 11; Vacancy Number: 2015-DALEX-B0297; Language in Vacancy Announcement that was Not Reflected in the Position Description*: None Qualification Factors in Vacancy Announcement that Were Narrowly Written: NoneRow 12; Vacancy Number: 2015-DALEX-B0310; Language in Vacancy Announcement that was Not Reflected in the Position Description*: None Qualification Factors in Vacancy Announcement that Were Narrowly Written: None: Row 13; Vacancy Number: 2015-DALEX-B0352; Language in Vacancy Announcement that was Not Reflected in the Position Description*: Authorizing FACTs cases under appropriate Loss Share Delegations of Authority. Those who make it through the process become part of an elite team that keeps our country safe. The Quality Review Procedures state that a subject-matter expert cannot also be an applicant.- DRR Selecting Officials Were Aware of Confidential Subject-Matter Expert Qualification Decisions. affiliation, sexual orientation, marital status, disability, We tested 83 applicant review sheets completed by DRR subject-matter experts in Dallas pertaining to the 10 Dallas vacancy announcements. Interview. The FDIC provides a wealth of resources for consumers, EXPLORE JOBS AT. In multiple cases, the inspector general said, the hiring process violated the FDIC’s own rules for processing applications. Based on our evaluation work and information gathered, however, we were not able to substantiate other allegations, as described in Appendix 3 of this report.Application Review Process Needs Improvement We identified several weaknesses in DOA and DRR’s review of applications related to potential conflicts of interest, maintaining confidentiality, ensuring adequate segregation of duties between DOA and DRR personnel, and non-compliance with DOA’s procedures for reviewing vacancy announcements (Quality Review Procedures).5 These weaknesses pertained to the 13 announcements in our sample and additional announcements that came to our attention.Footnote 5: Standard Operating Procedures for Quality Review of Applicants to Vacancy Announcements Posted on FDIC Careers, dated September 20, 2007. The procedures indicate that DOA must make the preliminary determination of which applicants are qualified. We assessed the roles that DOA human resources staff and DRR subjectmatter experts played in the FDIC’s hiring process for these positions.Scope and MethodologyThe scope of our evaluation focused on 13 vacancy announcements that were the subject of the complaints. No FDIC insurance years — and not tax deductible beginning in 2018) 5. The response is presented in its entirety in Appendix 6. The Federal hiring process is setup to be fair and transparent. Upon completion, the updated SOP will be communicated to Headquarters and Regional HR Staffing Team members. I liked FDIC; it was a quasi-private agency then. The Merit System Principles at 5 U.S.C. The U.S. government does not discriminate in employment on the Making a final decision regarding an applicant’s employment. The Merit System Principles at 5 U.S.C. OIG Analysis of Qualification Factors in Vacancy Announcements 4. DOA plans to conduct a similar audit in February 2018 and issue an audit findings report in April 2018.; Expected Completion Date: April 16, 2018 Monetary Benefits: No; Resolved:a Yes or No: Yes; Open or Closedb: OpenRow 5; Rec. DOA also noted that its human resources staff overruled subject-matter expert qualification determinations in some cases for 10 ten Dallas announcements.6Footnote 6: DOA records indicate that DOA overturned 29 out of 691 applicants (4 percent) of the subject-matter expert qualification decisions. FDIC Releases Diversity, Equity, and Inclusion Strategic Plan, Banking on Data: Great Possibilities, Great Responsibilities, The Importance of Community Banks in Paycheck Protection Program Lending, Career Transition Assistance Plan/Interagency Career We believe the work performed provides a reasonable basis for the conclusions in this report. Veteran Hiring for 13 Vacancy Announcements 2. Share. The purpose of a position description is to document the major duties and responsibilities of a position, not to spell out in detail every possible activity during the work day. Additionally, because the federal hiring process can take several months to advertise positions, interview candidates, and perform background and security screens, we strongly urge the FDIC to create a pool of vetted individuals who can readily fill vacancies in the Office on a case-by-case basis. LEARN MORE. The hiring process is chock full of potentially awkward moments. Acronyms and Abbreviations 6.
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