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#1679338 - 03/19/12 06:44 PM Senior Officer - defined???
Polo Offline
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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"?

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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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........
The opinions expressed here should not be construed to be those of my employer:

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