according to the proposed guidance:

·  “Covered Institutions are expected to update and modernize their policies and procedures to require vetting of Designated Persons—including senior officers and members of any governing board—both at onboarding and on a regular ongoing basis, to ensure a robust initial vetting and to confirm that no new circumstances or conflicts of interest have arisen that could compromise the organization.

·  “Covered Institutions should inform the Department promptly if, through character and fitness reviews, they determine that a previously vetted Designated Person is no longer fit to perform their current function, or they determine to transfer a Designated Person to another position or group or to make modifications to a Designated Person’s current functions on the basis of a character and fitness review.”

·  Another example: “[I]f an individual served as a Designated Person at a Covered Institution that has been subject to a regulatory action or proceeding—including, for instance, an enforcement action or a receivership or conservatorship proceeding—and if that individual then joins another Covered Institution, they should be subject to an enhanced review by the hiring Covered Institution, to ensure that the person did not play a significant role or otherwise contribute in a meaningful way to the conduct that led to such regulatory action or proceeding.”

· Comments are due by June 30, 2023.