Appendix A — Fit and Proper Criteria

Assess honesty, integrity and reputation; competence and capability; and financial soundness. Failure on one factor is not automatically determinative; consider seriousness, relevance to duties and time elapsed. Review regulatory discipline, criminal/civil proceedings, dishonesty, misrepresentation, complaints, prohibited status, unwillingness to comply, untruthfulness to regulators, insolvency, dismissal, competence/qualification, concurrent conflicts, bankruptcy, unsatisfied judgments, winding-up and receivership. Firms must have proper shareholders/directors/officers and recruitment/control processes.