The Institution's Security Program by BOL Guru Dana Turner
Your institution's board of directors should participate in the development and annual review of the Security Program. Regulation H requires that your directors ensure that a written Security Program for the institution's main office and branches is developed and implemented.
The literal Regulation H requirements for having a Security Program may not be enough for your institution. The regulatory language, except for reporting requirements, leaves you considerable flexibility in designing the Security Program. While this flexibility allows you to design a Security Program that truly meets the special needs of your institution, it also may promote the creation of a Security Program that -- while it meets regulatory standards -- is actually ineffective or even hazardous.
To be truly effective, your Security Program must contain policies and procedures that regulate the routine activities of every function and department within your institution. The goals of these policies and procedures must be to:
Reduce or eliminate the opportunity for mistakes, mistakes and crimes;
Protect all persons on the premises;
Identify and promote the prosecution of offenders; and
Recover missing, stolen or lost funds.
These policies and procedures should be designed to address:
Routine business operations;
Unusual or suspicious events that are not crimes; and
Your institution's potential exposure to the three types of internal and external crimes:
Crimes committed by document, device or technology;
Crimes committed by trickery or deceit; and
Crimes committed by force or fear.
Creating written policies and procedures for your institution should not be a complex task, although it may be a time-consuming one. If the process is complex, the resulting policies and procedures will be, also. Choose a format for creating your institution's security policies and procedures that complements the style of your existing manuals, workbooks, training guides and related documentation. Simply create an effective Security Program by making it:
Accurate in content;
Legal in application;
Reasonable and appropriate for your institution's needs;
Easy to understand;
Simple to use; and
An educational vehicle as well as a reference tool.
This article is part of a continuing series by Dana Turner on the role of the bank security officer.
Copyright, 2000, Dana Turner. All rights reserved.
Dana Turner is a principal with Security Education Systems, a consulting,
training and investigation firm located near San Antonio, Texas. Dana has served as a law
enforcement officer in several capacities, including the investigation of business
and banking crimes; as a community college instructor and administrator in
both the law enforcement and business management fields; and as a program
development specialist and trainer for private businesses, governmental
agencies and professional associations.
As a speaker and conference facilitator, Dana has acquired an excellent
reputation as a dynamic, knowledgeable and entertaining instructor. In
addition to his work with state banking associations, he designs and
participates in continuing education programs offered by the American
Bankers Association, Bank Administration Institute, Drug Enforcement
Administration, the Federal Financial Institutions Examination Council, the
Association of Certified Fraud Examiners and Bankers' Hotline.
As a writer, Dana has written many manuals and books, and numerous
newspaper, trade publication and magazine articles published and distributed
both nationally and internationally.
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