Is it possible to get feedback from viewers regarding 3 SAFE Act questons:

1) Who "owns" the SAFE Act policy? Compliance? H/R? Lending? Some other LOB Manager?

2) Regardless of who owns the policy, who is it in the bank who does the SAFE Act "stuff", including receiving the background check information, reviewing it, and managing it?

3) If there are any banks where a non-H/R person is doing the "stuff", how do you feel about non-H/R people seeing all that confidential background information, and has that ever been challenged by an employee or counsel?

Any feedback you provide is appreciated.

1- me (compliance)

2- me

3- just me. The second admin is our compliance officer, but I do it all. Hasn't been challenged by anyone...yet.

1-I (compliance) helped write it, but HR owns it.
2-HR manages it (CBC, registrations, tracking renewals, etc), I audit it.
3-No one has challenged my part in the process (audit).

HR handles it all.

Ditto Dani for our bank.

We are the same as Dani's bank.

1.) Me - Compliance (head of HR is the 2nd admin, but rarely involved at all)
2.) Same
3.) Nobody's said anything about it, but I wouldn't put much stock in that as far as decision making for any other institution. People here don't question much, and we rarely run anything past counsel to begin with

Ditto here (except for the annual audit--that's me)

Original Anon here.... after reviewing the responses it looks like either H/R or the Compliance department is an appropriate place for the SAFE Act policy ownership and the processing of the SAFE Act "stuff", with more responses for H/R. It doesn't seem like anyone has an issue with non-H/R people seeing confidential employee background info. Do you think size of the bank matters? We're in the $1 billion to $10 billion range.

Is there something that says only H/R people can see confidential employee background? (Within reason of course)

That being said we are a smaller community bank and we each wear many hats.

I'm going to chime in here only because I think I am missing something...

1.) I (compliance) own/modify the policy
2.) I review/manage the enrollment and background checks
3.) I have never had anyone show concern over the background check information. All that NMLS reports back is "pass or fail" with regards to the background check. I don't see the issue with it.

Maybe someday I'll get a "fail" and it will have a wrap-sheet.