NCUA Prohibits Two Individuals from Participating in the Affairs of Any Federally Insured Depository Institution

When regulators prohibit individuals from institution affairs, they are reversing an implicit decision that was made without a traceable record: the decision to grant and maintain that person's participation authority. A fitness determination is not a one-time HR event — it is an ongoing decision with an owner, evidence requirements, and a review cadence. The absence of a structured participation-authority log meant no one recorded the rationale for continued access, no one scheduled periodic fitness reviews, and no institutional memory existed to surface conduct patterns before they escalated to enforcement. Decision Governance treats access and authority as engineered artifacts, not assumed entitlements.