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#1679338 - 03/19/12 06:44 PM Senior Officer - defined???
Polo Offline
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Polo
Joined: Feb 2003
Posts: 178
12 CFR 334 Subpart J requires that a member of management at the level of "Senior officer" be appointed to oversee the Identity Theft Program.

Our bank has appointed an officer that does not carry such a title. However, the title "Senior" is generally applied internally and can mean different things at different banks.(ie, resposibility levels)

Does FCRA/ID Theft reg or any other reg define "Senior Officer"?
Also;

Would the level of responsibility of a compliance officer who is NOT at an internal bank level of even an AVP be criticised by examiners if he/she was given the ID Theft Prevention program appointment?
Would the bank need to show either by board approval or on paper that such a person is at the level of "Senior Officer" for it is nowhere else to be found?

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#1679547 - 03/20/12 04:19 AM Re: Senior Officer - defined??? Polo
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,901
Galveston, TX
It says they need to assign responsibility, not be necessarily be personally responsible. Sounds like you are the one that got tapped........
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