Sinners At The Pearly Gates: A Primer On The Standards Of Admission To The Banking Fraternity


Partner Pinchus D. Raice and Counsel David C. Thomas, both of Pryor Cashman’s Banking Group, have authored an article entitled "Sinners at the Pearly Gates - A Primer on the Standards of Admission to the Banking Fraternity." The article discusses variations of the “character and fitness” litmus test applied by the federal bank regulatory agencies to individuals seeking to become officers, directors or controlling shareholders of a federally insured depositary institution.

Raice and Thomas analyze the various formulations of the “fitness test” in the contrasting contexts of forming a de novo institution, acquiring an existing institution and resisting removal of an officer or director from an existing institution. They employ four hypothetical case studies – the Haggadah’s Four Sons – to explore frequently encountered obstacles to initiation into the banking fraternity.

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