On July 14, 2017, the Federal Deposit Insurance Corporation (FDIC) Office of Inspector General (OIG) issued an evaluation report regarding the FDIC’s process for filling certain time-limited positions in its Division of Resolutions and Receiverships (DRR). We conducted this evaluation in response to three Hotline complaints that we received in June and December 2015 alleging that certain DRR vacancy announcements posted in 2015 were too restrictive, resulting in the exclusion of veterans and other applicants from meeting required qualification factors. The complainants also alleged that DRR’s hiring process was not carried out in a fair and equitable manner. The hiring process is a joint responsibility between the FDIC’s Division of Administration (DOA) human resources personnel and DRR program officials, and both divisions need to ensure the hiring process is fair, follows FDIC policies, and helps defend against complaints or criticisms.
We substantiated aspects of the OIG hotline allegations and identified weaknesses in the FDIC’s process for filling certain time-limited positions. For example:
We identified several weaknesses in DOA and DRR’s review of applications. These weaknesses were related to potential conflicts of interest, maintaining confidentiality, ensuring adequate segregation of duties between DOA and DRR personnel, and non-compliance with DOA’s procedures for reviewing vacancy announcements.
- We identified process-related matters that were inconsistent with procedures; could have given applicants the perception that DRR, and not DOA, was administering the application review process; and/or posed risks that applicants could be erroneously included or excluded from certificates. In these instances, DRR subject-matter experts performed applicant qualification reviews before DOA human resources staff determined which applicants met eligibility requirements. DOA officials also did not consistently document their concurrence with subject-matter expert review decisions, as required by FDIC policy.
- We found that some qualification factors in 8 of the 13 vacancy announcements that we reviewed were not reflected in the related position descriptions, as required by FDIC policy. Using qualification factors that are grounded in position descriptions helps ensure that applicants are judged on factors that are fundamental to the position being filled and consistency in candidate evaluation and selection decisions.
- We noted that qualification factors in five vacancy announcements were narrowly written and limited the number of qualified applicants. For example, qualifications such as experience as a program administrator for developing a specific DRR system or being a member of a specific committee appeared to us to be narrowly focused and not essential to the related positions. Fewer qualified applicants were included in a certificate for these five announcements than for the eight announcements with qualification factors that we determined were not so specific.
Finally, we were not able to substantiate allegations that qualification factors were too restrictive because there was an absence of sufficient criteria for doing so. Also, based on information we gathered, we were not able to substantiate an allegation that DRR attempted to exclude qualified veterans from certificates.
We made five recommendations to DOA to address these findings. DOA concurred with our recommendations.