Quick Answer

Conditional. FirstBank Puerto Rico can hire individuals with felony convictions, but as an FDIC-insured depository institution, employment is subject to the strict federal requirements of Section 19 of the Federal Deposit Insurance Act (12 U.S.C. § 1829). With approximately 3,000+ employees across Puerto Rico, Florida, and the Virgin Islands, FirstBank is the largest locally headquartered bank in Puerto Rico, operating over 70 branches territory-wide.

A felony is not an automatic disqualifier. However, federal law prohibits the bank from employing anyone convicted of a crime involving dishonesty, breach of trust, or money laundering without an explicit written waiver from the FDIC. The Fair Hiring in Banking Act (FHBA), effective December 2022, significantly eased restrictions by creating automatic exclusions for older offenses, offenses committed before age 21, drug possession offenses, and de minimis offenses.

The greatest barriers are created by felonies related to financial crimes (fraud, embezzlement, identity theft), theft and dishonesty (burglary, forgery, counterfeiting), and breach of fiduciary duty (tax evasion, money laundering). Offenses less than seven years old face the highest scrutiny unless they qualify for FHBA exclusions.

The best opportunities exist for applicants whose offenses qualify for FHBA exclusions, eliminating the need for an FDIC waiver. Entry-level positions such as Service Representative (Teller), Customer Service Representative, and administrative support roles offer the most accessible pathways, with starting pay ranging from $14-$16/hr.

Table of Content

1. Quick Answer

2. Felon-Friendly Scorecard

3. Eligibility Checklist

4. Critical Regulatory Information

5. Company Overview

6. Hiring Policy Analysis

7. Background Check Process

8. Application Strategy

9. Tips for Applicants with Records

10. Benefits Overview

11. Frequently Asked Questions

12. Alternative Second Chance Employers

13. Conclusion

14. Disclaimer

Felon-Friendly Scorecard

Eligibility Checklist

Before applying, honestly assess whether you meet these baseline requirements:

• FHBA Exclusion Assessment: Determine if your conviction qualifies for an automatic FHBA exclusion (7+ years since offense, 5+ years since release from incarceration, offense committed before age 21 with 30+ months since sentencing, expunged/sealed records, or drug possession offenses). Qualifying exclusions eliminate the need for FDIC consent.

  
  

• Section 19 Compliance: If your offense involves dishonesty, breach of trust, or money laundering and does not qualify for an FHBA exclusion, you must obtain written FDIC consent before FirstBank can legally employ you. The bank cannot waive this federal requirement.

  
  

• Credit History: Must be prepared for a mandatory credit check. Unresolved financial issues such as bankruptcies, excessive debt, or patterns of financial irresponsibility may raise concerns for banking positions, though they are not automatic disqualifiers.

  
  

• Drug Screen: Must pass a mandatory pre-employment drug test. FirstBank maintains a drug-free workplace policy. Testing typically includes a standard multi-panel urine screening.

  
  

• Honesty is Paramount: Must be completely honest about your criminal record. Falsification is an automatic and permanent disqualifier in the banking industry and may constitute additional criminal violations under federal banking regulations.

  
  

• Work Authorization: Must be legally authorized to work in the United States and able to provide required I-9 documentation.

  
  

• Language Requirements: Bilingual proficiency in English and Spanish is highly preferred for most customer-facing positions in Puerto Rico.

Critical Regulatory Information

Understanding the regulatory framework governing criminal records in banking employment is essential for Second Chance applicants. FirstBank Puerto Rico, as an FDIC-insured institution, operates under federal banking regulations that supersede standard employment practices. The primary barrier is Section 19 of the Federal Deposit Insurance Act, which creates a lifetime prohibition on banking employment for individuals convicted of crimes involving dishonesty, breach of trust, or money laundering unless the FDIC grants written consent. The Fair Hiring in Banking Act (FHBA), effective December 23, 2022, significantly expanded exclusions from Section 19 prohibitions.

EEOC Guidelines

While the Equal Employment Opportunity Commission guidelines apply to FirstBank, the federal FDIC Section 19 requirements take precedence for banking-specific restrictions. Standard EEOC principles requiring individualized assessment and consideration of the Green Factors (nature and gravity of offense, time elapsed, nature of job sought) apply only to offenses not covered by Section 19. For covered offenses, FDIC consent is required regardless of EEOC factors.

FCRA Requirements

FirstBank must comply with the Fair Credit Reporting Act (FCRA) adverse action procedures:

(1) Provide pre-adverse action notice with a copy of the background report and summary of FCRA rights before making any adverse decision;

(2) Allow reasonable time (typically 5 business days) to dispute inaccuracies;

(3) Provide final adverse action notice if the decision stands after review. Additionally, the FDIC requires banks to make a reasonable, documented inquiry to verify applicant criminal history.

State-Specific Considerations

Puerto Rico does not have Ban the Box legislation, meaning employers may inquire about criminal history on initial job applications. However, the Puerto Rico Supreme Court has ruled that failing to hire based solely on criminal record may constitute social-condition discrimination. Florida, where FirstBank operates 8 branches, also lacks comprehensive Ban the Box protections for private employers, though some localities have local ordinances. The U.S. Virgin Islands and British Virgin Islands locations follow federal guidelines.

Banking Industry-Specific Considerations

The banking industry operates under strict federal regulations that create unique barriers. FDIC Section 19 prohibits employment of persons convicted of crimes involving dishonesty, breach of trust, or money laundering without FDIC written consent.

The FHBA created automatic exclusions effective October 1, 2024:

(1) Offenses that occurred 7+ years ago;

(2) Release from incarceration 5+ years ago;

(3) Offenses committed before age 21 with 30+ months since sentencing;

(4) Expunged, sealed, or dismissed convictions;

(5) Drug possession offenses (simple possession and possession with intent to distribute);

(6) De minimis offenses (fake ID, shoplifting, trespass, fare evasion, driving with expired license) if 1+ year since conviction;

(7) Misdemeanor dishonesty offenses committed 1+ year before application. Certain federal offenses (18 U.S.C. specified crimes) still require 10-year prohibition regardless of FHBA exclusions.

Company Overview

FirstBank Puerto Rico is the banking subsidiary of First BanCorp (NYSE: FBP), a publicly traded financial holding company headquartered in San Juan, Puerto Rico. Founded in 1948 as First Federal Savings and Loan Association, FirstBank was the first savings and loan institution established in Puerto Rico. The bank has grown through strategic acquisitions including Chase Manhattan Bank operations in the U.S. Virgin Islands (2000), UniBank Florida (2005), Virgin Islands Community Bank (2008), and Banco Santander Puerto Rico (2020). Today, FirstBank operates approximately 75 branches across Puerto Rico, Florida, the U.S. Virgin Islands, and British Virgin Islands.

FirstBank provides comprehensive financial services including commercial and consumer banking, mortgage banking, automobile financing, trust services, and insurance through FirstBank Insurance Agency. The company employs over 3,000 employees and is committed to community involvement through partnerships, educational programs, and corporate donations. The bank emphasizes internal career growth through its internal job posting policy and development programs.

Company Fast Facts

• Founded: 1948 (San Juan, Puerto Rico)

• Headquarters: San Juan, Puerto Rico (1519 Ponce De Leon Avenue)

• Employees: 3,000+ across Puerto Rico, Florida, and Virgin Islands

• Total Assets: $18.9 billion (September 2024)

• Revenue: $880 million (2024)

• Stock Exchange: NYSE (Symbol: FBP)

• CEO: Aurelio Aleman

• FDIC Certificate: #30387

• Branch Network: 56 branches in Puerto Rico, 8 in Florida, 11 in U.S. and British Virgin Islands

Hiring Policy Analysis

FirstBank Puerto Rico operates under mandatory federal FDIC requirements that govern criminal background screening for all banking positions. Unlike standard employers, the bank must make a reasonable, documented inquiry into each applicant's criminal history as required by FDIC regulations. Background checks are conducted after conditional job offer, giving applicants the opportunity to demonstrate qualifications before criminal history is reviewed. The bank's hiring process includes online application, phone screening, in-person interviews, conditional offer, background and credit check, drug screening, and final hiring decision.

Position-Specific Barriers

Barrier levels in banking are primarily determined by the nature of the criminal conviction relative to Section 19 covered offenses, rather than by specific job duties. All positions are subject to FDIC Section 19 requirements.

Available Positions and Pay

Pay data compiled from Glassdoor, Indeed, PayScale, and FirstBank job postings. Actual compensation varies by location, experience, and role complexity.

Career Path Examples

FirstBank emphasizes internal career growth through its internal job posting policy and development programs. The "Best of ONE" recognition program rewards employee performance.

Branch Operations Track: Service Representative ($15-$16/hr) → Senior Teller ($17-$19/hr) → Head Teller ($19-$22/hr) → Assistant Branch Manager ($35K-$45K/yr) → Branch Manager ($43K-$60K/yr). Requires 2-4 years at each level with consistent performance.

Customer Service Track: Customer Service Representative ($14-$16/hr) → Senior CSR ($17-$19/hr) → Team Lead ($20-$24/hr) → Call Center Supervisor ($40K-$55K/yr). Strong performance metrics and leadership skills required.

Collections Track: Consumer Collector ($15-$18/hr) → Senior Collector ($18-$22/hr) → Collections Specialist ($22-$26/hr) → Loss Mitigation Analyst ($40K-$55K/yr). Strong negotiation and analytical skills valued.

Background Check Process

FirstBank conducts comprehensive background checks as required by FDIC regulations. The bank must make a reasonable, documented inquiry to verify each applicant's criminal history before employment.

• What They Check: Criminal history (felonies and misdemeanors) at county, state, and federal levels with focus on Section 19 covered offenses; credit history and financial responsibility; identity verification through SSN trace and address history; employment history verification; education verification for positions requiring specific credentials; drug screening (mandatory for all positions).

  
  

• Lookback Period: FHBA excludes offenses 7+ years old from Section 19 coverage. Employment verification typically extends 7-10 years. Credit history review covers standard reporting periods. Certain federal offenses under 18 U.S.C. require 10-year prohibition regardless of FHBA exclusions.

  
  

• Timeline: The hiring process averages 2-4 weeks from application to hire. Background checks typically take 1-2 weeks after conditional offer. Positions requiring FDIC waiver applications may take significantly longer (60-90 days or more for waiver processing).

  
  

• Process Flow: Application submitted → Phone screening → Interview(s) → Conditional offer → Background check and drug test authorization → Criminal and credit checks conducted → Section 19 review → FHBA exclusion determination → FDIC waiver application if required → Results reviewed → Final hiring decision → Pre-adverse or adverse action notice if applicable → Start date confirmed.

Disqualifying Factors

Automatic Bars (Section 19 Covered, No FHBA Exclusion): Recent convictions (within 7 years) involving dishonesty, breach of trust, or money laundering including fraud, embezzlement, forgery, counterfeiting, identity theft, money laundering, tax evasion, and similar offenses. Certain specified federal crimes carry 10-year prohibition regardless of other factors.

High Risk (May Require FDIC Waiver): Theft-related offenses depending on circumstances and timing; financial crimes within lookback period; offenses involving breach of fiduciary responsibility.

Lower Risk (FHBA Exclusions May Apply): Drug possession offenses (simple possession, possession with intent to distribute); de minimis offenses (fake ID, shoplifting, trespass, fare evasion); offenses committed before age 21 with 30+ months since sentencing; expunged, sealed, or dismissed convictions; misdemeanor dishonesty offenses 1+ year old.

Your Rights as Applicant

• FCRA Protections: You must receive written notice and provide consent before a background check. If denied based on the report, you're entitled to a copy and the right to dispute inaccuracies with the reporting agency.

  
  

• Pre-Adverse Action Notice: Before a final decision, you must receive notice with a copy of the report and a summary of your rights. You have at least 5 business days to dispute inaccuracies or provide additional information.

  
  

• FHBA Exclusion Rights: If your offense qualifies for an FHBA exclusion, you have the right to employment without requiring FDIC consent. The bank must properly evaluate whether exclusions apply before requiring a waiver.

  
  

• FDIC Waiver Rights: If a waiver is required, you may apply individually or have the bank sponsor your application. The FDIC must consider rehabilitation evidence and cannot automatically deny based solely on the offense.

Application Strategy

1. Assess FHBA Exclusion Eligibility First: Before applying, determine if your conviction qualifies for automatic FHBA exclusion. Calculate whether 7+ years have passed since the offense, 5+ years since release from incarceration, or if the offense was committed before age 21 with 30+ months since sentencing. Drug possession and de minimis offenses may also qualify.

   
   

2. Target Entry-Level Positions: Focus on Service Representative (Teller), Customer Service Representative, and administrative support positions. These roles offer the best opportunity to demonstrate reliability. Avoid management or compliance positions initially if your record is recent.

   
   

3. Apply Through Official Channels: Submit applications through FirstBank's careers website at 1firstbank.com/careers. Create a complete profile highlighting skills, bilingual abilities, and any relevant customer service experience. Check the careers page regularly as positions are posted frequently.

   
   

4. Be Completely Honest: Never lie about your criminal history. In banking, dishonesty is an automatic and permanent disqualifier. Falsification may also constitute additional federal violations. Wait until asked or until after conditional offer to discuss your record.

   
   

5. Prepare Your Narrative: Have a brief, honest explanation ready: acknowledge the offense without making excuses, describe what you learned, and explain how you've changed. For banking positions, emphasize your understanding of integrity and financial responsibility.

   
   

6. Document Rehabilitation Thoroughly: Gather evidence of positive changes: completion of any required programs, educational certificates, stable employment history, resolution of financial issues, community involvement, and character references. This documentation is essential if FDIC waiver is required.

   
   

7. Research Expungement Options: Expunged, sealed, or dismissed convictions are excluded from Section 19 under FHBA. Research whether your offense qualifies for expungement under Puerto Rico, Florida, or applicable state law. Contact legal aid organizations for assistance.

   
   

8. Address Credit Issues: Banking positions require credit checks. Before applying, check your credit report, dispute any errors, and work to resolve outstanding issues. Demonstrating financial responsibility is particularly important for banking employment.

Tips for Applicants with Records

1. Banking Has High Integrity Standards: Understand that banking is one of the most heavily regulated industries regarding criminal backgrounds. Section 19 restrictions exist to protect consumers and the financial system. Respect for these standards demonstrates maturity.

   
   

2. FHBA Changed the Landscape: The Fair Hiring in Banking Act effective December 2022 significantly expanded opportunities. Many offenses that previously required FDIC waivers are now automatically excluded. Don't assume you're disqualified based on outdated information.

   
   

3. Run Your Own Background Check: Know exactly what will appear before FirstBank sees it. Order your criminal background and credit reports from consumer reporting agencies. Dispute any errors well in advance of applying.

   
   

4. Develop Bilingual Skills: English and Spanish bilingual proficiency is highly valued for Puerto Rico positions and can make you a more competitive candidate. If you need to improve language skills, invest in this before applying.

   
   

5. Pass the Drug Test: If you have substance issues, address them completely before applying. FirstBank requires drug testing for all positions. Note that under FHBA, drug possession offenses are now excluded from Section 19 coverage.

   
   

6. Demonstrate Financial Responsibility: Work on improving your credit score and resolving outstanding debts. Open and maintain bank accounts responsibly. Demonstrating you can manage your own finances is critical for banking employment.

   
   

7. Consider FDIC Waiver Process: If your offense requires an FDIC waiver, understand that the process exists and many waivers are granted. The FDIC considers rehabilitation evidence and individual circumstances. Strong documentation increases approval chances.

   
   

8. Build Customer Service Experience: Gain customer service experience in other industries first if needed. Retail, hospitality, or call center experience demonstrates you can handle customer interactions professionally and builds transferable skills.

Benefits Overview

FirstBank offers a comprehensive benefits package to full-time employees. Benefits eligibility typically begins after the introductory period.

• Compensation: Competitive base salary with bonus opportunities. Stock purchase plan allows employees to purchase FirstBank stock without commissions or transaction fees. Annual performance-based raises reported by employees.

  
  

• 401(k) and Retirement: 401(k) retirement savings plan with opportunity for emergency fund savings. Details on employer matching vary by position and tenure.

  
  

• Health Benefits: Three medical plan options to choose from based on individual needs. Dental, vision, and prescription drug coverage included. Supplemental coverage available for catastrophic conditions. Cancer insurance and other critical illness coverage offered.

  
  

• Life Insurance: Life insurance coverage 100% paid by FirstBank for eligible employees.

  
  

• Time Off: Paid vacation (10-20 days reported), personal days, sick leave. Marriage leave, paternity/maternity leave, family medical leave, bereavement leave, jury duty leave, and military leave available.

  
  

• Professional Development: Digital training platform with virtual and in-person development workshops. Performance management program aligning objectives with career advancement. Educational assistance for continuing academic studies.

  
  

• Recognition Programs: "The Best of ONE" corporate recognition program rewards employee performance and contributions.

  
  

• Employee Perspectives - Pros: Good benefits package; job stability; professional environment; internal growth opportunities; community involvement through volunteer programs.

  
  

• Employee Perspectives - Cons: Pay could be more competitive; some report limited advancement in certain departments; work-life balance varies by role; high performance expectations.

Frequently Asked Questions

1. Does FirstBank Puerto Rico hire people with felonies?

   Yes, but with significant federal restrictions. As an FDIC-insured bank, FirstBank must comply with Section 19 of the Federal Deposit Insurance Act. The Fair Hiring in Banking Act (FHBA) now excludes many offenses from Section 19 requirements, including offenses 7+ years old, drug possession offenses, de minimis offenses, and expunged records. For covered offenses not qualifying for exclusions, FDIC written consent is required before employment.

   
   

2. What is the background check process at FirstBank Puerto Rico?

   FirstBank conducts comprehensive background checks after conditional job offer as required by FDIC regulations. Checks include criminal history at county, state, and federal levels; credit history review; identity verification; employment verification; and drug screening. The bank must make a "reasonable, documented inquiry" and evaluate whether offenses are covered by Section 19 and whether FHBA exclusions apply.

   
   

3. How far back does the background check go at FirstBank Puerto Rico—what is the lookback period?

   Under FHBA, offenses that occurred 7+ years ago are generally excluded from Section 19 coverage. Offenses where incarceration ended 5+ years ago also qualify for exclusion. However, certain specified federal crimes under 18 U.S.C. carry a 10-year prohibition period. Employment verification typically extends 7-10 years, and credit history follows standard reporting periods (7-10 years).

   
   

4. What types of convictions make hiring more difficult at FirstBank Puerto Rico?

   Crimes involving dishonesty, breach of trust, or money laundering create the highest barriers and are specifically covered by Section 19. These include fraud, embezzlement, forgery, counterfeiting, identity theft, money laundering, tax evasion, and similar offenses. Recent offenses (within 7 years) in these categories that don't qualify for FHBA exclusions require FDIC consent. Drug possession, traffic offenses, and de minimis offenses generally present lower barriers.

   
   

5. What are the best entry-level roles at FirstBank Puerto Rico for applicants with a record?

   Service Representative (Teller) positions at $15-$16/hr offer the most hiring volume. Customer Service Representative roles at $14-$16/hr are also frequently available. Administrative support and facilities positions may have slightly lower scrutiny for non-dishonesty offenses. All positions remain subject to Section 19 requirements, but FHBA exclusions significantly expand opportunities.

   
   

6. Does FirstBank Puerto Rico drug test, and what kind of test do they use?

   Yes, FirstBank requires pre-employment drug screening for all positions as part of its drug-free workplace policy. Testing typically involves a standard multi-panel urine test. Note that under FHBA, drug possession convictions (including simple possession and possession with intent to distribute) are now excluded from Section 19 coverage.

   
   

7. When during the hiring process will FirstBank Puerto Rico ask about criminal history?

   Puerto Rico does not have Ban the Box legislation, so employers may inquire about criminal history on initial applications. However, most banking employers conduct formal criminal background checks after extending a conditional job offer. FirstBank evaluates qualifications during the interview process and conducts comprehensive background screening after conditional offer.

   
   

8. Can someone advance to management at FirstBank Puerto Rico if they have a felony?

   Advancement is possible if the individual was properly hired under Section 19 requirements (either through FHBA exclusion or FDIC waiver). Management positions carry higher fiduciary responsibility and face increased scrutiny. Consistent performance, demonstrated integrity, and professional development through FirstBank's training programs support advancement. FDIC waiver approval typically covers all positions at FDIC-insured institutions.

9. How long does the hiring and background check process take at FirstBank Puerto Rico?

   The standard hiring process takes approximately 2-4 weeks from application to start date. Background checks typically complete within 1-2 weeks after conditional offer. If FDIC waiver application is required, the process extends significantly—waiver applications may take 60-90 days or longer for FDIC review and decision.

   
   

10. What can applicants do to improve their chances of getting hired at FirstBank Puerto Rico?

    First, determine if your conviction qualifies for FHBA exclusion. Second, pursue expungement or sealing if eligible under applicable law. Third, develop bilingual English/Spanish proficiency. Fourth, resolve any credit issues and demonstrate financial responsibility. Fifth, gain customer service experience in other industries. Sixth, prepare thorough rehabilitation documentation. Seventh, be completely honest throughout the process—integrity is paramount in banking.

Alternative Second Chance Employers

If FirstBank doesn't work out, consider these employers known for fair chance hiring practices in Puerto Rico and the financial services industry:

Conclusion

FirstBank Puerto Rico offers conditional opportunities for individuals with criminal records, though the banking industry's strict federal regulations create significant barriers not found in other industries. As the largest locally headquartered bank in Puerto Rico with over 3,000 employees and 75 branches, the organization provides substantial employment opportunities for those who can navigate the Section 19 requirements.

The Fair Hiring in Banking Act substantially improved prospects by creating automatic exclusions for older offenses, drug possession crimes, de minimis offenses, and expunged records. Many individuals previously barred from banking employment may now qualify without needing FDIC consent. Entry-level positions such as Service Representative (Teller) and Customer Service Representative at $14-$16/hr offer the most accessible pathways.

Key Success Factors: Determine FHBA exclusion eligibility before applying; pursue expungement if available; demonstrate financial responsibility; develop bilingual skills; maintain absolute honesty throughout the process; prepare thorough rehabilitation documentation.

Biggest Barriers: Recent convictions (within 7 years) involving dishonesty, breach of trust, or money laundering that don't qualify for FHBA exclusions; poor credit history; failure to disclose criminal record (automatic permanent disqualifier); specified federal crimes carrying 10-year prohibition.

For those whose offenses qualify for FHBA exclusions or who can obtain FDIC consent, FirstBank offers stable employment, comprehensive benefits, and genuine career advancement opportunities. The comprehensive benefits package, internal promotion policies, and community-focused culture make it a worthwhile target for qualified Second Chance applicants willing to meet the high integrity standards required in banking.

Disclaimer

This guide provides general information and should not be considered legal advice. Hiring policies vary by position, location, and individual circumstances. While we strive for accuracy using publicly available sources including company websites, FDIC regulations, job postings, employee reviews (Glassdoor, Indeed), and salary databases (PayScale, ZipRecruiter), employment information and company policies may change without notice. FDIC Section 19 requirements and FHBA exclusions involve complex legal determinations that should be confirmed with legal professionals.

Inclusion in this guide does not guarantee employment. Background check laws, FDIC waiver procedures, expungement rules, and fair chance hiring requirements vary by jurisdiction and individual circumstances. Consult with an employment attorney or legal aid organization for specific legal advice about your situation. FDIC waiver applications involve detailed procedures not fully covered in this guide.

Apply Now: https://www.1firstbank.com/pr/en/about-us/careers.html