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#112678 - 09/05/03 08:36 PM Security officer
Nick Offline
Junior Member
Joined: Sep 2003
Posts: 37
I am wondering if there is a conflict of interest or any problems with the Compliance Officer be the Security officer.
What I say is strictly my thoughts.

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Security - PUBLIC
#112679 - 09/05/03 08:48 PM Re: Security officer
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
If the Compliance Officer's testing includes the Security Officer's duties within the scope then you have a slight problem. One cannot test oneself and be unbiased. However, if you are a small shop, you sometimes have to wear two or more hats. So, in a case like this, perhaps the Internal Auditor could be relied on to perform testing of the Security Officer's function.
If you keep living straight from the heart, you will know when to stop and to start.

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#112680 - 09/08/03 04:11 PM Re: Security officer
Red Offline
Gold Star
Joined: Dec 2002
Posts: 345
New England
This is the first year our compliance officer and security officer are the same people. Our outsourced IAs don't have a problem with it. It has not been subject to regulatory review, yet. However, I believe it does pose an issue with time. I think our SO/CO spends more time on security(since security issues need to be handled NOW) and compliance slips to the back burner. I don't think its a conflict, but I think, depending on bank size and structure, it could be too much job for one person.
Its risky business, but someone has to do it.

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#112681 - 09/08/03 08:52 PM Re: Security officer

Nick, you do not mention your asset size or the type of institution and/or complexities. Assuming you're from an under-$500 million institution with moderate (but not significant) security risks, having the two positions converge should not be a problem. However, that being said, the security officer's expanded role in filing SARs for more potential risks; the annual reporting to the board; the likelihood of having disaster planning responsibilities, etc., mean that at some point the positions tied together will pose a personal strain on you -- but what else is new in smaller shops. You'll either do it and complain; or you'll not do it, be a hero, and not be working! Good luck.

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#112682 - 09/10/03 01:44 PM Re: Security officer
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
We are a $400 million dollar bank and I've been both for 7 problems.......
Riding the waves of change.....2014

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#112683 - 09/12/03 01:36 PM Re: Security officer
RBanker Offline
Power Poster
Joined: Jul 2003
Posts: 2,675
Austin Texas
For the past 2+ yeaers, our Compliance and Security Officer has been one and the same person, and nothing has been said in any of our exams, either internal, Texas Dept of Banking, or FDIC - so they evidently son't see a problem with it.
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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