Posted By: Polo
Senior Officer - defined??? - 03/19/12 06:44 PM
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?
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?