The Security Officer's Role, Part VIII
The role of the financial institution's Security Officer is different from any other industry. Banking is the most regulated industry in the United States. Every year, and particularly since 911, laws are passed that directly affect banking compliance and security areas. In addition, some laws affecting national security necessitate the issuing of regulations by the various banking regulatory agencies that must be complied with by all financial institutions. The well trained, prepared security director will be conversant with all the following:
Laws, Rules & Regulations
- All anti-money laundering regulations;
- All collections law and regulations;
- All criminal laws and facility safety ordinances in your state that are appropriate for the Security Department;
- All electronic funds transfer regulations;
- Americans With Disabilities Act;
- Bank Bribery Act;
- Bank Protection Act
- Bank Secrecy Act and Suspicious Activity Reports;
- Fair Credit Reporting Act;
- Financial Institution Recovery, Reform and Enforcement Act;
- Gramm-Leach-Bliley Act;
- Interagency Policy Statement on Contingency Planning;
- Polygraph Protection Act;
- Occupational Safety & Health Administration regulations;
- Regulation H (or its equivalent for your industry);
- Right To Financial Privacy Act;
- Rules of Evidence (state and federal codes);
- Uniform Commercial Code;
- USA Patriot Act; and
- Workplace Illness & Injury Prevention Program regulations (applicable in several states).
Security Practices & Resources
- Conducting an investigation and interviewing conduct;
- Corporate investigative guidelines;
- Criminal justice components as they exist in your community (law enforcement, courts and corrections);
- Disciplinary actions and related policy and procedures;
- Domestic and workplace violence;
- Investigative report writing;
- Legal counsel and filing security-related reports;
- Searches of employees and customers;
- Sexual (or other) harassment or discrimination;
- Subpoenas and search warrants; and
- We-Tip or other anonymous reporting service.Searching and using www.BankersOnline.com will help you track down resources for all of the above.
Get Some HelpAs the Security Officer, you face significant legal and operational challenges in your attempts to provide a safe and secure environment for employees to work - and for customers to do business. Your best allies are the institution's Auditor, Human Resources Manager, Compliance Officer and Legal Counsel. With their input to the overall security policies and procedures, the people filling these positions may provide an effective check and balance system - to insure that appropriate prevention, identification, apprehension, prosecution and recovery strategies are developed and implemented in all areas of your financial institution.
Consult with your Auditor, Human Resources Manager, Compliance Officer and Legal Counsel before developing policies and procedures that may affect other departments, functions, facilities and business units within the institution. Consult with them as you develop the institution's Security Program. They will help you to analyze the likely short-term and long-term effects of your plans. Getting them on board early also helps ensure the success and maintenance of security procedures - an important part of your overall plan.
Whatever your Legal Counsel advises you to do - do it, after you get that legal opinion in writing, of course.
SummaryAre you having a difficult time justifying the effort, expense, time and manpower necessary to create an effective Security Program?
First, take a look at your own experience. Chances are if you've been a security officer for any length of time, you have a good handle on all of the subjects on the lists above. It may be time to "redo" your resume - if only to give yourself confidence.
Second, when dealing with administration resistance to incorporating security procedures, remind them to consider that your institution's ability to attract and retain qualified personnel and customers is directly related to your institution's professional image and reputation. This image is based upon trust and confidence - and the perception by both employees and customers of safety and soundness. Making sure that trust and confidence stays strong and sure is part of your job.
A professional reputation takes years to acquire, moments to destroy - and an eternity to rebuild. Inappropriate and ineffective operational procedures used by your employees may destroy your institution's image - and they are among the easiest operational mistakes to prevent. If your institution already has a Security Program, review it and assure yourself and your Board of Directors that it really meets your institution's needs. Because so much about the security function concerns safety - employees' and other persons' - simply meeting minimum regulatory requirements shouldn't be the goal.
The Security Director must have adequate training, and it is also important that he/she has been granted sufficient power, authority and insurance to match the assigned responsibilities and liabilities. The support of administration and the Board of Directors is critical in order to provide and maintain a safe and secure working environment. Becoming a professional - and effective - Security Officer requires special education, training and skills. It isn't a role for everyone. But if you approach the job with the right blend of enthusiasm, dedication and humor, you can easily become one of your institution's most valued assets.
(This series of training pages is for new or experienced Security Officers. Dana Turner is a security practitioner and author of the Financial Institution Security Library. He is a moderator on BankersOnline.com's Security Forum and a frequent contributor to the Bankers' Hotline. Contact Dana at (830) 535-6500 or at firstname.lastname@example.org)
Copyright © 2005 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 15, No. 3, 4/05
First published on 04/01/2005