Vetting your C-Level Management Part 2: Federal Criminal Records and Credit Reports

written on April 15, 2011 by Ted L Moss

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Most companies do not order background checks that include searches at the federal level, or credit reports, as a standard practice.  Federal records are held at federal district, appellate, and bankruptcy courts.  Examples of federal criminal records include interstate crimes, crimes against the government such as counterfeiting, bank robbery, kidnapping, and mail fraud.  Other federal records include bankruptcy and some civil cases involving remedies for negligence, civil rights violations, and antitrust activity.

The federal court system has a public access website called PACER (Public Access to Court Electronic Records).  This is a fee based search engine, which searches the federal court system.  Federal records are not difficult to obtain, but because they normally lack identifiers, such as date of birth or social security number, it takes some expertise to verify that the information obtained relates to the person you are investigating. 

When conducting background check on C-Level executive placements, some of the normal restrictions of the Fair Credit Employment Act (FCRA) do not apply.  For example, the FCRA restricts the use of a credit report in the screening process for positions that do not conform to “permissible purpose” specifications, except for those positions paying 75K or above.

In the normal course of hiring, access to credit reports is restricted to employers who can demonstrate a permissible purpose.  An example of a permissible purpose would include hiring for a position that has direct access to company or customer financial information.  The credit report that is received for this purpose is a modified credit report, otherwise known as a credit header.  It does not include a credit score, but it does show defaults and bill payment history.  This restriction is waived for those positions with a compensation level of $75,000 and above.

When conducting pre-employment screening for entry level positions, a federal record search may not be cost effective.  When hiring for a C-Level executive position, a search of federal records and a request for a credit report is prudent; especially to identify criminal records relating to white collar crime.