Conflicts of Interest in the Acquisition Process

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to complete a conflict of interest certification in which each team member is to assess and document that they do not have a potential or actual conflict of interest related to the specific acquisition prior to participating in any phase of the acquisition lifecycle (from planning to closeout). These procedures should require that evidence of acquisition team members’ conflict of interest certifications is maintained in accordance with requisite FDIC records retention schedule requirements.