The Office of the Comptroller of the Currency
But an investigation conducted by
Through a Freedom of Information Act request to the OCC, Roddan found that Bhardwaj had listed C-level technology roles at several large banks on his CV. He also found that Bhardwaj hadn't worked at any of them.
"On his resume, Bhardwaj claimed he was the chief information officer at Ohio-based Fifth Third Bank between 2006 and 2010, a role that reported to the chief financial officer and oversaw a $330 million budget," Roddan wrote. "The bank — one of the largest consumer banks in the midwest — never employed Bhardwaj, a spokesperson said."
Roddan reported that Bhardwaj's resume stated he was a director of information technology at Citi between 1994 and 2000, but that the bank has no record of his employment.
"He also claimed to have held the role of chief information officer and digital transformation officer at Ohio-based Huntington Bank from 2010 to 2015, reporting to the CEO and the board and managing a $250 million budget while overseeing a team of more than 500 employees," Roddan wrote. "However, the position of chief information officer was held by other people during that time period. One of the men who held the role said he had never heard of Bhardwaj. Huntington declined to comment." Bhardwaj could not be reached for comment.
An internal memo Roddan saw listed the prior roles Bhardwaj cited. The public press release did not mention any of them.
Sources also told Roddan that Bhardwaj is 42, belying the "30 years of financial industry experience" the OCC cited in its March press release.
In response to several questions about Bhardwaj and the OCC's hiring and vetting process, an OCC spokeswoman said, "the OCC does not comment on personnel issues."
Acting Comptroller of the Currency Michael Hsu mentioned Bhardwaj in an
Industry observers were shocked that the OCC had hired someone whose resume contained falsehoods that could have been easily uncovered in a background check.
"Quite frankly, this aspect of this incredible story is the most gobsmacking," said Michele Alt, co-founder and managing director at Klaros Group. "Large banks are subject to continuous, on-site supervision by OCC exam teams." In other words, the OCC has examiners embedded full-time at Huntington, Citi and Fifth Third.
"They are also subject to specialty IT exams," Alt said. "These teams would have interacted with the banks' CIOs and other senior IT managers. I am very surprised that Bhardwaj's vetting did not include checking with these exam teams."
Some wonder about Bhardwaj's motive and mindset.
"The question that fascinates me is Bhardwaj's psychology," said Todd Baker, a senior fellow at the Richman Center for Business, Law & Public Policy at Columbia University and managing principal of Broadmoor Consulting. "How did he ever think he was going to get away with this? Once he was inside the OCC, his claims that he had held senior executive positions at Fifth Third and Huntington would inevitably be exposed as false by the banks themselves and the examiners covering those companies. What was the point of the whole thing?"
The OCC faces challenges in hiring senior technology leaders, Alt noted.
"The OCC — like all government agencies — cannot pay market rates for this talent," she said. According to The Information, Bhardwaj was paid a $300,000 salary.
This is not enough to attract top tech talent.
"A $300,000 salary seems like a lot, but a senior bank tech executive would be paid five times as much," Baker said. "So I can understand why the OCC jumped when this guy's resume crossed someone's desk. But sometimes something seems too good to be true because it is, and the hiring process clearly failed here. That's the lesson for the agency going forward."
Technology oversight is not the OCC's primary job, Alt pointed out.
"Most OCC examiners have finance, accounting and similar degrees that are highly relevant to the OCC's core bank supervision mission," Alt said. "These OCC professionals are talented and dedicated, but they are not themselves technologists. This can make it difficult for the OCC to evaluate a candidate's technology chops."
But more than anything else, Bhardwaj's hire suggests a due diligence failure, she said.
"Vetting — rather than a bigger hiring budget or technological prowess — was the only thing necessary to uncover the lies in Bhardwaj's employment application," Alt said.
Alt also worries that Bhardwaj was given access to highly sensitive systems and data. "If the OCC were a bank, it would be cited for a violation of the interagency guidance on third-party relationships, which requires a bank to conduct due diligence on third parties before onboarding them," she said.
Baker warns against using this incident to discredit the OCC.
"While this is deeply embarrassing for the OCC, it isn't the first time that a brazen fabulist has fooled smart people before being found out nor should it be used as an excuse to chase Acting Comptroller Hsu out of office or stymie the Biden regulatory agenda," he said.
