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#112678 - 09/05/03 08:36 PM Security officer
Nick Offline
Junior Member
Joined: Sep 2003
Posts: 37
Kentucky
I am wondering if there is a conflict of interest or any problems with the Compliance Officer be the Security officer.
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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.
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#112680 - 09/08/03 04:11 PM Re: Security officer
Red Offline
Gold Star
Red
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.
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#112681 - 09/08/03 08:52 PM Re: Security officer
Anonymous
Unregistered

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 years.....no problems.......
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#112683 - 09/12/03 01:36 PM Re: Security officer
RBanker Offline
Power Poster
RBanker
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.
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