I would like to revive this thread. It seems that the FDIC has been telling banks in the West that these need to be separate positions. I am the Compliance Officer for a bank with 20 branches, approximately $4 billion in assets. I have no IT background and I am being asked to assume the ISO position. I do not feel that this is appropriate. For starters, I do not have the experience and secondly, I already have enough responsibilities.
Kathy, can you explain why it is acceptable for a small bank to have the positions combined, but not for a larger complex bank? What exactly is the issue? The fact that I have to ask this question clearly indicates my ignorance, and explains why I am uncomfortable with the idea. If I had the appropriate background, I would likely understand the reason for the segregation.
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PorcelainDoll
CRCM