Sample Background Check Policy Report for a Bank Teller in New York City
This page shows a complete sample background check policy report from our policy builder for a financial institution. A fictional savings bank with 210 employees entered one position, a bank teller at a Brooklyn branch. In return, the builder applied 40 federal, New York, and New York City rules and wrote the draft policy language below. Read the guide first, then scroll through the full report exactly as the bank received it.
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The scenario behind this sample background check policy
Every report starts with a short questionnaire. For this sample, a fictional employer, Fivepenny Savings Bank, described a full-time bank teller. The teller works at one branch in Brooklyn, handles cash, and sees confidential customer data. Moreover, the bank employs 210 people, uses a background screening company, and already has a written policy. It plans county, statewide, federal, and national database searches, plus a global watchlist search. It also plans a credit report and employment, education, and reference checks.
This employer does most things right. It asks about criminal history only after a conditional offer, and it uses a written individualized assessment. However, three answers still draw attention. The bank wants to consider sealed records and to look back without limit, and it uses an automated screening tool. Consequently, the report lists two process changes and adds New York City’s rules for automated tools. In contrast to the restaurant supervisor sample, this is a report for a mature program.
| Input | What the company entered | Why it changes the report |
|---|---|---|
| Position | Bank Teller, full-time, hourly at $24 for 40 hours a week | Pay of about $49,920 a year lifts New York’s seven-year limit. However, the federal limit on non-conviction records stays in force. |
| Employer | Private savings bank, financial services, 210 employees | Size triggers Title VII and the New York City laws. The industry brings FDIC Section 19 screening. |
| Work site | One branch in Brooklyn (Kings County), New York; headquarters in New York | New York State law applies, and the New York City Fair Chance Act adds timing, analysis, and notice duties. |
| Duties | Access to cash and to confidential customer data; check required by Section 19 of the Federal Deposit Insurance Act | The duties support a credit report under a documented exemption. They also shape the job-related offense list. |
| Checks planned | County, statewide, federal, national database, and watchlist searches; credit report; employment, education, and reference checks; an automated screening tool | The report confirms the package. It also requires a bias audit and candidate notice before the automated tool is used. |
| Gaps | Wants to consider sealed records; no limit on the lookback | Both become items in “Your process: what to change.” The first is required, and the second is recommended. |
How to read the report
Each recommendation is a card with a colored label and a plain-English instruction. A source line cites the statute, regulation, or guidance behind it. Therefore, your employment counsel can verify every item without re-researching it. The four labels tell you how much weight each card carries.
A law that applies to this position requires or prohibits the step. Where two laws conflict, the report shows the strictest one as required.
No statute compels the step, but skipping it creates real legal risk. Most of these come from EEOC guidance and negligent-hiring case law.
A step that well-run screening programs take everywhere. This sample has none, because every item rose to a higher label.
Context the bank needs: which laws apply and why, how FDIC Section 19 works, and the draft policy language itself.
The strictest rule wins
This teller is covered by federal law, New York State law, and New York City law at the same time. Instead of listing three versions of each rule, the report picks the most protective one. For example, New York State has no ban-the-box law for private employers. New York City, however, bars any criminal history inquiry until after a conditional offer. As a result, the report shows the conditional-offer rule as required.
Gaps become a change list
Near the end, the section “Your process: what to change” repeats only the cards where current practice falls short. Here it lists two items. Remove sealed records from the criteria, and adopt a written seven-year lookback. Additionally, the numbered draft policy folds every required item into language the bank can adopt.
What the sections cover
The report has 13 sections in a fixed order. It opens with the FCRA steps every employer must follow. Then it explains which laws apply and when the company may ask about criminal history. Next, it covers which records count and how far back to look. After that come notices, the search package, credit reports, drug testing, salary history, and other checks. Finally, it lists the process changes, the draft policy, and a color-coded checklist of what is in place and what to add.
The sample report: Bank Teller, New York City
Below is the full report, rendered as HTML. The cards match what the company saw on screen and in its 14-page PDF. The employer and contact are fictional. However, every rule, citation, and date is real and current as of October 1, 2026. Use the chips to jump to a section.
Start hereLaws applied to this positionWhen you may ask about criminal historyWhich records you may considerHow far back you may lookIndividualized assessment and required noticesRecommended searches for this positionEmployment credit reportsDrug and marijuana testingSalary historyOther checks and verificationsYour process: what to changeDraft policy language for this positionYour answersChecklist
Bank Teller
Required or prohibited by law 17Strongly recommended to reduce legal risk 10Best practice 0Informational reminder 13
Jurisdictions applied
Start here: the foundation of every screening policy
These items apply to every position you screen. Put them in place before anything else.
Stand-alone disclosure and signed authorization before every report
Before you order any report from a background screening company, give the applicant a written disclosure that consists solely of the statement that a consumer report may be obtained for employment purposes, and get a signed (or e-signed) authorization. Keep waivers, extra terms, and state notices off the disclosure page; put state-required language on a separate page. Certify to the screening company that you have done this and will follow the adverse-action rules.
Source: 15 U.S.C. § 1681b(b)(2) Read the law →
Apply the same screening package to every applicant for the same position
Order the same searches and apply the same written decision criteria to every applicant for this position. Deviations by individual (for example, checking one candidate’s credit but not another’s) are the most common source of discrimination claims, and Title VII disparate-treatment liability attaches to employers with 15 or more employees. Document any exception and the business reason for it.
Source: Title VII; EEOC Enforcement Guidance (2012) Read the law →
Two-step adverse action before any rejection based on a report
If a report may lead you to reject an applicant, first send a pre-adverse action notice with a copy of the report and the CFPB Summary of Rights, then wait at least five business days for the applicant to respond, and only then send the final adverse action notice naming the screening company, stating that it did not make the decision, and explaining the right to dispute and to a free copy within 60 days.
Source: 15 U.S.C. §§ 1681b(b)(3), 1681m Read the law →
Keep a written background screening policy and adverse-action procedure
A written policy that names the searches ordered for each position, the timing, the decision criteria, the individualized-assessment steps, and the adverse-action sequence is what regulators and plaintiffs ask for first. Update your existing policy with the position-specific items below.
Source: EEOC guidance; state requirements
When rules conflict, the strictest one wins
This position is subject to 3 layers of law (federal, state, and local). Where they differ, follow the most protective rule for the applicant; that is the rule shown as “required” below. Recommendations are current as of October 1, 2026.
Keep the file
Keep the disclosure, authorization, report, assessment notes, and notices for at least one year after the decision (two years for federal contractors); several laws require longer (Maryland four years, Los Angeles and San Francisco three years, Massachusetts CORI acknowledgments one year with a dissemination log). Store reports separately from the personnel file and dispose of them securely.
Source: 29 C.F.R. § 1602.14; FTC Disposal Rule Read the law →
Laws applied to this position
Federal law
The Fair Credit Reporting Act governs every report prepared by a screening company; Title VII and the EEOC’s 2012 guidance govern how criminal history may be used (15 or more employees); the ADA governs the timing of medical examinations.
Source: 15 U.S.C. § 1681 et seq.; 42 U.S.C. § 2000e Read the law →
New York state law
Applied because work is performed in Brooklyn, Kings County, New York. No statewide ban-the-box law for private employers, but Article 23-A bars denying employment because of a conviction unless there is a direct relationship to the job or an unreasonable risk, after weighing eight factors. New York City (four or more employees), Buffalo and Suffolk County (15 or more), Rochester (four or more), and Westchester County require waiting until after a conditional offer or the application stage.
Source: N.Y. Correction Law art. 23-A; Exec. Law § 296(15)–(16); local fair-chance laws Read the law →
New York City ordinance
Employers with four or more employees may not ask about or search criminal history (including pending cases and arrests) until after a conditional offer, and job ads may not exclude people with records. Non-criminal checks must be completed before the offer; the criminal check comes after. To withdraw an offer, complete the written Fair Chance Analysis on the Commission’s form using the Article 23-A factors (or the NYC factors for pending cases and post-hire conduct), give the applicant the report and the analysis, and hold the position open for at least five business days. Covers current employees and independent contractors.
Source: N.Y.C. Admin. Code § 8-107(11-a) (Fair Chance Act, as amended July 29, 2021) Read the law →
When you may ask about criminal history
Wait until after a conditional offer of employment
Ask about, search for, or consider criminal history only after a conditional offer of employment. This is the strictest timing rule among the laws that apply to this position (New York City). Because a law, licensing board, contract, or bond requires a check for this position, the statutory exemption may let you ask earlier; the safer course, and the one most regulators expect, is to keep the check after the conditional offer and rely on the exemption only for the substance of the decision.
Source: N.Y.C. Admin. Code § 8-107(11-a) (Fair Chance Act, as amended July 29, 2021) Read the law →
Remove criminal-history language from job ads and applications
Delete the conviction question from the application form and remove statements such as “no felonies” or “clean record required” from postings; most fair-chance laws (for example Colorado, New Jersey, Vermont, Maine, Washington, New York City, Philadelphia, Los Angeles, and Seattle) treat such statements as violations. Where the law requires it (Los Angeles County, Philadelphia), the posting must instead state that criminal history will be reviewed after a conditional offer.
Source: State and local fair-chance laws Read the law →
Run non-criminal checks first
Sequence the order: identity and SSN trace, employment and education verification, license checks, and any permitted credit or MVR check before or with the offer; order the criminal search only once the conditional offer has been made. New York City and Los Angeles County make this sequencing mandatory.
Which records you may consider
Never consider sealed, expunged, set-aside, or pardoned records
You selected these records as ones you want to consider. Remove them: Applicants may lawfully deny that these records exist, and screening companies may not report them. Clean-slate laws now seal eligible records automatically in many states, so a record that appeared on a report last year may be off-limits this year. Sealed records, including records sealed under the Clean Slate Act, may not be requested or used (Exec. Law § 296(16)); only employers required to fingerprint for specified positions may see them.
Source: State sealing and expungement statutes Read the law →
Never consider juvenile records
Juvenile adjudications are confidential in every state that applies to this position and may not be requested or used: Youthful-offender adjudications and juvenile records may not be asked about or used.
Source: State juvenile-records statutes; FCRA § 605 Read the law →
Do not consider arrests, dismissed charges, or pre-trial diversions that did not end in a conviction
New York: Employers may not ask about or act on arrests or accusations that did not result in a conviction and are not pending, adjournments in contemplation of dismissal, youthful-offender adjudications, sealed violations, or sealed convictions (Exec. Law § 296(16)). New York City bars consideration of arrests and non-convictions. Exception: FDIC-insured institutions must still screen for pretrial diversions involving dishonesty under Section 19 of the FDI Act.
Source: State fair-employment and arrest-record statutes Read the law →
Pending charges: job-related conduct only, and re-verify before deciding
Pending charges may generally be considered when the alleged conduct relates to the job, but do not treat a charge as a conviction. New York City requires the Fair Chance analysis for pending cases. Re-check the disposition before any final decision.
Source: State fair-chance laws Read the law →
Convictions: consider only those that relate to this job
Felony and misdemeanor convictions may be considered, but only through the individualized assessment described below and only where the offense relates to the duties of a Bank Teller. Blanket exclusions (“no felonies”) are unlawful in the fair-chance jurisdictions that apply here and are treated as presumptively discriminatory by the EEOC everywhere.
Source: EEOC Enforcement Guidance (2012); state fair-chance laws Read the law →
Write job-related criteria for this position
Given the duties you described, the offense categories with a defensible relationship to this job are: theft, fraud, embezzlement, forgery, identity theft, and computer crimes. Put these categories, the time limits, and the assessment factors in a written screening matrix for the position so every reviewer applies the same standard.
Source: EEOC Enforcement Guidance (2012) Read the law →
How far back you may look
Recommended lookback: seven years
No state seven-year cap covers this position. New York’s seven-year limit (N.Y. Gen. Bus. Law § 380-j(f)) is lifted for this position because it is expected to pay at least $25,000. Under the federal FCRA, convictions may be reported at any age; arrests and other non-convictions may not be reported after seven years. Recommended scope: seven years. The EEOC treats older records as weaker evidence of risk, and a fixed written limit is easier to defend than open-ended review. An unlimited lookback is the hardest position to defend; adopt a written limit.
Source: 15 U.S.C. § 1681c; EEOC Enforcement Guidance (2012) Read the law →
Salary and the seven-year rule
Because this position is expected to pay $49,920, below the $75,000 federal threshold, screening companies may not report arrests, civil judgments, collections, or other non-conviction adverse items older than seven years. State thresholds (for example $20,000 in Kansas, New Hampshire, and Washington; $25,000 in New York; $75,000 in Maryland and Texas; none in California, Colorado, Massachusetts, Montana, or New Mexico) are applied above where relevant.
Source: 15 U.S.C. § 1681c(b)(3) Read the law →
Individualized assessment and required notices
Written individualized assessment is mandatory here
Before withdrawing an offer because of a record, document the nature and gravity of the offense, the time elapsed, and the nature of the job, give the applicant the record and your preliminary reasoning, wait the required period, consider any response, and then issue a final written decision. New York: Weigh the eight Article 23-A factors: the public policy of encouraging employment, the specific duties of the job, the bearing of the offense on fitness, the time elapsed, the applicant’s age at the time, the seriousness of the offense, evidence of rehabilitation and good conduct, and the employer’s legitimate interest in protecting property and safety. Employers with 10 or more employees must, on request, give a written statement of reasons within 30 days. New York City: Employers with four or more employees may not ask about or search criminal history (including pending cases and arrests) until after a conditional offer, and job ads may not exclude people with records. Non-criminal checks must be completed before the offer; the criminal check comes after. To withdraw an offer, complete the written Fair Chance Analysis on the Commission’s form using the Article 23-A factors (or the NYC factors for pending cases and post-hire conduct), give the applicant the report and the analysis, and hold the position open for at least five business days. Covers current employees and independent contractors.
Source: N.Y. Correction Law §§ 752–754; N.Y.C. Admin. Code § 8-107(11-a) (Fair Chance Act, as amended July 29, 2021) Read the law →
New York notices and forms
When a consumer report contains a criminal conviction, the user must give the subject a printed or electronic copy of Article 23-A of the Correction Law (Gen. Bus. Law § 380-g(d)). Under the Clean Slate Act, every entity that receives criminal history information from DCJS for civil purposes (fingerprint-based checks) must give the individual a copy of that information together with Article 23-A and inform them of the right to seek correction of inaccurate information (Exec. Law § 845-d(5)). New York City Fair Chance Act: after a conditional offer, complete the written Fair Chance Analysis on the Commission’s form, give the applicant a copy of the report and analysis, hold the position open for at least five business days, and consider any response before withdrawing the offer. Investigative-report notices under N.Y. Gen. Bus. Law art. 25 apply.
Source: N.Y. Correction Law art. 23-A; Exec. Law § 296(15)–(16); local fair-chance laws Read the law →
Recommended searches for this position
County criminal search: current and prior counties of residence
The county court is the source of record; order a search in each county where the applicant has lived or worked in the lookback period, identified through an SSN trace and address history. Statewide and national databases supplement, not replace, county searches.
Source: Industry standard; FCRA § 613 accuracy duties
Statewide repository search where the state offers one
Add the statewide search for each work and residence state that has a usable repository; it catches counties the address history misses. Some states (California, for example) have no public statewide search, and repository data quality varies.
Federal criminal search
Federal district court records (fraud, embezzlement, tax, securities, and computer crimes) do not appear in county or state searches. The duties of this position make a federal search worthwhile.
Database results must be verified at the source before you act on them
A national multi-jurisdictional database is a locator tool. Before any adverse decision, the record must be confirmed against the court of record (the FCRA requires screening companies to keep public-record information complete and current, and several states bar reliance on unverified database hits). Never reject on a database-only result.
Source: 15 U.S.C. § 1681k Read the law →
Global watchlist / OFAC search
Sanctions, terrorist, and debarment lists (OFAC, SAM, OIG, FINRA, Interpol) are inexpensive and expected in regulated and government-facing roles.
Mandated checks for your industry control the substance of the decision
You identified a required check: Section 19 of the Federal Deposit Insurance Act (12 U.S.C. 1829). Section 19 of the Federal Deposit Insurance Act (12 U.S.C. § 1829) bars FDIC-insured institutions from hiring anyone convicted of, or in a pretrial diversion for, a crime of dishonesty, breach of trust, or money laundering without FDIC consent. The Fair Hiring in Banking Act (Pub. L. 117-263 § 5705, Dec. 23, 2022), implemented by the FDIC at 12 C.F.R. part 303 subpart L (effective Oct. 1, 2024), excludes from the bar offenses that were expunged, sealed, or dismissed, designated lesser offenses and de minimis offenses (including bad checks totaling $2,000 or less), and offenses more than seven years old, or more than five years after release from incarceration, or committed at age 21 or younger with 30 months since sentencing; institutions must still make a reasonable, documented inquiry into criminal history before hiring. NCUA applies a parallel rule to credit unions (12 U.S.C. § 1785(d); 12 C.F.R. part 752, effective Oct. 30, 2024). FINRA Rule 3110(e) requires member firms to investigate the character and background of applicants for registration and to verify Form U4 information, including a search of reasonably available public records, within 30 days of filing. A mandated fingerprint or regulator check does not replace the FCRA process when a screening company is also used, and most fair-chance timing exemptions cover only the mandated check itself.
Source: Industry-specific federal and state rules
Employment credit reports
New York: credit report allowed only under a documented exemption
A credit report is permitted for this position in New York only under an exemption. Your answers support: access to trade secrets or confidential information. Employers, labor organizations and employment agencies may not request or use consumer credit history for hiring, compensation, or other terms of employment; ‘consumer credit history’ covers a credit report, a credit score, and information obtained directly from the individual about credit accounts, bankruptcies, judgments or liens. Exemptions: use required by state or federal law or a self-regulatory organization; police, peace-officer, and law-enforcement positions; appointed positions of high public trust requiring a state background investigation; bonded positions; positions requiring a security clearance; non-clerical positions with regular access to trade secrets, intelligence or national-security information; positions with signatory authority over third-party funds or assets of $10,000 or more or fiduciary authority to enter financial agreements of $10,000 or more for the employer; and positions whose regular duties allow the employee to modify digital security systems. State and local agencies may not use credit history for licensing unless required by law (§ 380-b(e)). New York City’s law has parallel exemptions. Record the exemption in the position file, state the basis on the disclosure where the law requires it, and never use credit as the sole reason for rejection.
Source: N.Y. Gen. Bus. Law §§ 380-a, 380-b(d)–(e) (S. 3072 / A. 1316, ch. 681 of 2025, signed Dec. 19, 2025, effective Apr. 18, 2026); N.Y.C. Admin. Code § 8-107(24) (Stop Credit Discrimination in Employment Act) Read the law →
New York City: credit report allowed only under a documented exemption
A credit report is permitted for this position in New York City only under an exemption. Your answers support: access to trade secrets or confidential information and financial institution. Employers with four or more employees may not request or use consumer credit history unless an exemption applies: required by law or a self-regulatory organization, police or peace officers, positions requiring a security clearance, non-clerical positions with regular access to trade secrets or national-security information, positions with signatory authority over $10,000 or more in third-party funds, positions that modify digital security systems, and positions subject to Department of Investigation background checks. Record the exemption in the position file, state the basis on the disclosure where the law requires it, and never use credit as the sole reason for rejection.
Source: N.Y.C. Admin. Code § 8-107(24) (Stop Credit Discrimination in Employment Act, 2015) Read the law →
FDIC Section 19 screening
Section 19 of the Federal Deposit Insurance Act (12 U.S.C. § 1829) bars FDIC-insured institutions from hiring anyone convicted of, or in a pretrial diversion for, a crime of dishonesty, breach of trust, or money laundering without FDIC consent. The Fair Hiring in Banking Act (Pub. L. 117-263 § 5705, Dec. 23, 2022), implemented by the FDIC at 12 C.F.R. part 303 subpart L (effective Oct. 1, 2024), excludes from the bar offenses that were expunged, sealed, or dismissed, designated lesser offenses and de minimis offenses (including bad checks totaling $2,000 or less), and offenses more than seven years old, or more than five years after release from incarceration, or committed at age 21 or younger with 30 months since sentencing; institutions must still make a reasonable, documented inquiry into criminal history before hiring. NCUA applies a parallel rule to credit unions (12 U.S.C. § 1785(d); 12 C.F.R. part 752, effective Oct. 30, 2024). FINRA Rule 3110(e) requires member firms to investigate the character and background of applicants for registration and to verify Form U4 information, including a search of reasonably available public records, within 30 days of filing.
Source: 12 U.S.C. § 1829 Read the law →
Drug and marijuana testing
No drug testing planned
You indicated no drug testing for this position. If you add it later, re-run the builder: several of the jurisdictions here restrict marijuana testing and require written policies.
Salary history
Do not ask about salary history
New York — Employers may not ask about or rely on salary history; employers with four or more employees must include pay ranges in postings (Sept. 17, 2023). New York City — Employers may not inquire about or rely on salary history; pay ranges must appear in postings (Nov. 1, 2022). Remove the question from applications and interview scripts, and tell your screening company not to request prior pay during employment verification.
Source: N.Y. Labor Law § 194-a (Jan. 6, 2020); § 194-b (pay ranges in postings, employers with four or more employees, Sept. 17, 2023); N.Y.C. Admin. Code § 8-107(25) (Oct. 31, 2017) Read the law →
Other checks and verifications
Employment verification
Confirm dates, titles, and eligibility for rehire. Do not ask prior employers for pay history where a salary-history ban applies (and Massachusetts and Washington extend the ban to screening vendors).
Education verification
Verify degrees with the registrar or clearinghouse and check the institution against diploma-mill lists; a false degree claim is a stronger and more defensible basis for rejection than most criminal records.
Automated or AI screening tools are regulated here
New York — New York City employers using an automated employment decision tool to screen candidates must obtain an independent bias audit within the past year, publish a summary, and give candidates notice at least 10 business days before use. Statewide, the Division of Human Rights applies disparate-impact rules to algorithmic tools. New York City — An automated employment decision tool may be used to screen candidates for a New York City job only if it has had an independent bias audit within the past year, a summary of the audit is published, and candidates receive notice at least 10 business days before use, including the qualifications and characteristics the tool assesses and the right to request an alternative process. Ask your vendor for the bias audit, the notice language, and the human-review process before using the tool for this position.
Source: N.Y.C. Admin. Code § 20-870 et seq. (Local Law 144, July 5, 2023); N.Y.C. Admin. Code § 20-870 et seq. (Local Law 144, enforced July 5, 2023) Read the law →
E-Verify is voluntary for this position
E-Verify is voluntary under federal law except for federal contractors with the FAR E-Verify clause (48 C.F.R. 52.222-54: enroll within 30 days of award, verify new hires within three business days of hire, and verify existing employees assigned to the contract). Every employer must still complete Form I-9 for each new hire: Section 1 by the first day of work and Section 2 within three business days of the first day of work (8 C.F.R. § 274a.2). The current Form I-9 is the 01/20/25 edition (expires 05/31/2027); USCIS also accepts the 08/01/23 edition through 05/31/2027. Several states mandate E-Verify for private employers above a size threshold; the state rule is shown where it applies.
Source: 8 C.F.R. § 274a.2; 48 C.F.R. 52.222-54 Read the law →
Your process: what to change
Never consider sealed, expunged, set-aside, or pardoned records
See “Which records you may consider” above. You selected these records as ones you want to consider. Remove them: Applicants may lawfully deny that these records exist, and screening companies may not report them. Clean-slate laws now seal eligible records automatically in many states, so a record…
Source: State sealing and expungement statutes Read the law →
Recommended lookback: seven years
See “How far back you may look” above. No state seven-year cap covers this position. New York’s seven-year limit (N.Y. Gen. Bus. Law § 380-j(f)) is lifted for this position because it is expected to pay at least $25,000. Under the federal FCRA, convictions may be reported at…
Source: 15 U.S.C. § 1681c; EEOC Enforcement Guidance (2012) Read the law →
Draft policy language for this position
Background Screening Policy — Bank Teller
1. Purpose and scope. [Company Name] conducts background screening for the position of Bank Teller to verify qualifications, protect employees, customers, and property, and comply with applicable law. This policy applies to all applicants for the position. The same searches and criteria apply to every candidate for the position.
2. Consent. Before any report is obtained from a consumer reporting agency, the candidate receives a stand-alone written disclosure and provides written authorization. State-required notices are provided on a separate page. [Company Name] certifies its compliance to the screening company.
3. Timing. Criminal history is not requested on the application or in job advertisements. [Company Name] asks about, searches for, and considers criminal history only after a conditional offer of employment. Non-criminal checks (identity, employment, education, license, credit) are completed first.
4. Searches. The screening package for this position consists of: county criminal court search in each county of residence and employment during the lookback period; statewide criminal search where available; federal criminal search; national criminal database and sex-offender registry search, with all results verified at the source; employment credit report, where permitted under the exemption documented in the position file; employment verification; education verification; references verification. The lookback period is seven years. Records older than the lookback period, sealed, expunged, set-aside, or pardoned records, juvenile records, and arrests or charges that did not result in a conviction (other than pending charges whose alleged conduct relates to the position) are not considered. Pre-trial diversions that ended in dismissal are not considered. Deferred adjudications are treated as non-convictions and are not considered.
5. Decision criteria. A conviction is considered only if it relates to the duties of the position. For a Bank Teller, the offense categories with a documented relationship to the job are listed in the position screening matrix. No candidate is rejected automatically because of a record.
6. Individualized assessment. Before withdrawing an offer because of a record, the hiring manager and Human Resources document the nature and gravity of the offense, the time elapsed since the offense or completion of the sentence, and the nature of the position; provide the candidate with the record and the preliminary reasons; allow at least 5 business days for the candidate to respond with evidence of inaccuracy, rehabilitation, or mitigating circumstances; consider the response; and issue a final written decision.
7. Adverse action. If a report may lead to an adverse decision, [Company Name] sends a pre-adverse action notice with a copy of the report and the Summary of Rights, waits the period in section 6, and then sends a final adverse action notice that names the screening company, states that the screening company did not make the decision, and explains the candidate’s dispute rights and right to a free copy of the report.
8. Credit reports. A credit report is obtained for this position only because [state the exemption: managerial position / signatory authority / regular access to cash or financial accounts / access to trade secrets / bonded position / required by law]. The basis is stated on the disclosure where the law requires it, and credit history is never the sole reason for an adverse decision.
9. Salary history. [Company Name] does not ask candidates or prior employers about compensation history. Offers are based on the budgeted range for the position.
10. Records and confidentiality. Screening reports and assessment records are stored separately from personnel files, accessible only to those involved in the decision, retained for [one / two / four] years after the decision, and then securely destroyed.
11. Review. This policy and the position screening matrix are reviewed at least annually and whenever the position, its work locations, or applicable law changes. Rules current as of October 1, 2026.
Source: Draft for review by counsel
Your answers
The questionnaire answers that produced this report, exactly as the company entered them.
| Job title | Bank Teller |
| What type of employer are you? | Private company |
| How many employees do you have across all locations? | 210 |
| Is your organization in any of these regulated industries? | Financial services, banking, or insurance |
| Will the background check be obtained from a background screening company (a consumer reporting agency) or run in-house by your staff? | Screening company |
| Where will this position perform its work? | At a fixed work site |
| Work site location | Brooklyn, Kings County, New York |
| Where is your company headquartered? | New York |
| Who is being screened? | New applicant |
| Employment status | Full-time |
| Is this a managerial or executive position, or exempt from overtime under the FLSA? | No |
| Does the position involve any of the following? | Access to cash, checks, or company financial accounts; Access to confidential customer data, trade secrets, or personal information |
| Will the applicant drive as part of the job? | No |
| Is this a safety-sensitive position under federal law, state law, or your own written policy? | No |
| Is a background check for this position required by a federal or state law, a licensing board, a government contract, or a bonding or insurance requirement? | Yes |
| Does the position require a security clearance or work on a federal contract? | No |
| Does the position require a professional license or certification? | No |
| How is this position paid? | Hourly |
| Expected annual compensation | $49,920 (from hourly rate × hours × 52) |
| Will you ask the applicant about their prior salary or wage history? | No |
| Will you run a criminal history check? | Yes |
| Which criminal searches do you plan to run? | County courts (current and prior residences); Statewide repository; Federal district courts; National multi-jurisdictional database; Global watchlists / OFAC |
| Which record types do you want to consider? | Felony convictions; Misdemeanor convictions; Pending charges; Sealed, expunged, or pardoned records |
| How far back do you want to look? | No limit |
| When do you currently ask about criminal history? | Only after a conditional offer |
| Will you use a written individualized assessment (nature of the offense, time elapsed, relation to the job) before rejecting an applicant because of a record? | Yes |
| Will you apply the same criteria to every applicant for this position? | Yes |
| Will you request an employment credit report? | Yes |
| Why is a credit report needed for this position? | Regular access to cash or financial accounts; Access to trade secrets or confidential information; Financial institution |
| Will you drug test? | No |
| Which verifications will you run? | Employment history; Education; Personal or professional references |
| Will you pull a motor vehicle record (MVR)? | No |
| Will you review the applicant’s social media or other public internet content? | No |
| Will any automated, algorithmic, or AI-based tool be used to score, rank, or screen applicants or background reports? | Yes |
| Will you rescreen employees or use continuous monitoring after hire? | No |
| Will you check federal exclusion lists (OIG, SAM)? | No |
| Has the applicant lived, worked, or studied outside the U.S. in the past 7 years? | No |
| At what stage do you currently run the background check? | After a conditional offer |
| Do you give applicants a stand-alone FCRA disclosure and get written authorization before ordering the report? | Yes |
| When a report leads you to reject someone, do you send a pre-adverse action notice, wait, and then send a final adverse action notice? | Yes, both notices |
| What would you like the builder to produce? | Both |
Your screening policy checklist
Green: already in place. Amber: recommended addition. Red: required addition.
- Stand-alone FCRA disclosure and signed authorization You give the stand-alone disclosure and get written authorization before every report.
- Two-step adverse action (pre-adverse notice, wait, final notice) You send both notices and wait the required period.
- Timing of the criminal-history question You ask only after a conditional offer of employment, which meets the strictest rule that applies here.
- Written screening policy and adverse-action procedure You keep a written policy and procedure; update it with the position-specific items in this report.
- Written individualized assessment before any rejection You document the nature of the offense, the time elapsed, and the relation to the job before deciding.
- Same searches and criteria for every applicant You apply one package and one set of criteria to every applicant for the position.
- Record types limited to what the law allows Add to your policy: never consider sealed, expunged, set-aside, or pardoned records.
- Lookback period within the legal limit Recommended: adopt a written seven-year lookback.
- No salary-history questions You do not ask applicants or prior employers about pay history.
- Credit report use Your credit-report use fits an exemption that applies here.
- E-Verify and Form I-9 E-Verify is not mandated for this position; Form I-9 is still required for every hire.
- Automated or AI screening tools Recommended: confirm the vendor bias audit, notice language, and human review before using any automated tool.
Important
This report is general compliance information prepared from the laws in effect on the date shown. It is not legal advice and does not create an attorney-client relationship. Laws change frequently and local rules may add requirements; confirm the recommendations with your employment counsel before adopting a policy. screeningpolicy.com and Langley Porter AG LLC do not make hiring decisions and are not a law firm.
What a bank does with this background check policy report
A bank already has compliance staff, so the report works as an independent check on the current policy. Compliance generates it and counsel reviews it. Then HR updates the policy and briefs the screening vendor. Each step below takes less time than the research it replaces.
Send it to counsel
Forward the PDF to your employment lawyer. Every card cites its source, so review takes minutes rather than billable days.
Fix the change list
Work through “Your process: what to change.” Here that means removing sealed records from the criteria and adopting a seven-year lookback.
Brief your vendors
Order the confirmed package with source verification. Then ask the vendor of the automated tool for its bias audit and notice language.
Document the credit exemption
Record the exemption that supports the credit report in the position file. Then update the written policy and calendar an annual review.
Why a bank with a written policy still needs a position-specific report
Two credit laws at once
New York State and New York City each restrict employment credit reports. A teller’s credit report is allowed only under a documented exemption. The report names the exemptions the answers support and tells the bank to record the basis in the position file.
Banking law meets fair-chance law
Section 19 bars hiring people with certain dishonesty offenses without FDIC consent. Meanwhile, the city’s Fair Chance Act requires a written analysis and five business days before an offer is withdrawn. The report explains how both apply to the same hire.
Automated tools are regulated
New York City requires an independent bias audit within the past year for automated hiring tools. It also requires a published summary and notice to candidates ten business days before use. The report flags all three, because the bank said it uses such a tool.
Sample background check policy report: frequently asked questions
What is a sample background check policy report?
It is a real output of our policy builder for one job position, shown here as an example. The report lists every federal, state, and local screening rule that applies to the position. It labels each one by weight, cites its source, and ends with draft policy language. This sample covers a bank teller at a 210-employee savings bank in Brooklyn, New York City.
Is Fivepenny Savings Bank a real employer?
No. The bank and the contact name are fictional, and the answers were chosen to show a typical financial-institution hiring scenario. However, every rule, citation, penalty amount, and effective date is real. All of them are current as of the date printed on the report.
Can a New York City bank run a credit report on a teller?
Only under a documented exemption. New York State and New York City both restrict employment credit reports. For this teller, the report says the answers support an exemption, such as access to confidential information. Therefore, the bank must record the exemption in the position file. It may never use credit history as the sole reason for rejection.
What do the red, amber, green, and blue labels mean?
Red means a law requires or prohibits the step. Amber means the step is strongly recommended to reduce legal risk, usually under EEOC guidance or negligent-hiring case law. Green marks a best practice with no legal driver. Blue marks a reminder that gives context, such as which laws apply or how long to keep records.
What is FDIC Section 19 screening?
Section 19 of the Federal Deposit Insurance Act bars insured institutions from hiring certain people without FDIC consent. It covers convictions and pretrial diversions for dishonesty, breach of trust, or money laundering. The Fair Hiring in Banking Act narrowed the bar for older, sealed, and minor offenses. Nevertheless, the bank must still make a reasonable, documented inquiry before hiring.
When may a New York City employer ask about criminal history?
Only after a conditional offer. The New York City Fair Chance Act covers employers with four or more employees. Non-criminal checks must be finished before the offer, and the criminal check comes after. To withdraw the offer, the employer completes the written Fair Chance Analysis. It then holds the job open for at least five business days.
Why can’t the bank consider sealed records?
New York bars employers from asking about or using sealed records, including records sealed under the Clean Slate Act. The bank selected sealed records as something it wanted to consider. Consequently, the report marks their removal as a required change. Only employers required to fingerprint for specified positions may see them.
What does the report say about automated or AI screening tools?
New York City regulates automated employment decision tools. A tool may screen candidates for a city job only after an independent bias audit within the past year. The employer must also publish a summary and notify candidates at least ten business days before use. The report tells the bank to get all three from its vendor.
Can I use the draft policy language as written?
Treat it as a draft for counsel, not a finished policy. Fill in the bracketed fields, such as the company name and the retention period. Then attach the screening matrix and have your employment lawyer confirm the language. The report is general compliance information and not legal advice.
How do I get a report for my own position?
Open the policy builder, answer the questionnaire for one position and its work locations, and pay $25. The report appears on screen instantly and arrives by email as a PDF. Nothing you enter is stored on our servers.
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Enter the position, the pay, and every place the person will work. Our engine compiles the applicable federal, state, and local screening laws and returns a color-coded report with draft policy language. Then your counsel reviews it and signs off.
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ScreeningPolicy.com is operated by Langley Porter AG LLC. Reports are general compliance information, not legal advice, and do not create an attorney-client relationship. Confirm every recommendation with your employment counsel before adopting a policy.