Answer by Andy Zavoina:
No.The SO needs the authority to function adequately, but the title is up to the bank.
Answer by Dana Turner:
To my knowledge, there's no regulation or law that requires the Security Officer to be an officer of the institution. But, unless you ARE an officer, the institution's D&O insurance likely won't cover you for acts performed. There are two (2) solutions to this issue if you're not an officer with fiduciary responsibilities:
- Get the institution to make you at least an AVP (good luck), or;
- Have the institution attach a rider to your existing insurance policy that will cover you for acts performed as the Security Officer only.
Either coverage presumes that you have an appropriate position description in place for the coverage to take effect. I've forwarded two (2) tools to BOL for posting that may help you:
- "The Security Officer's Role", a comprehensive treatment of what the Security Officer's duties really entail -- and lists the ideal candidate's qualifications; and
- A sample Security Officer's Position Description.
Please recognize that these tools simply reflect "the security world according to Dana" and that it's unlikely that any institution will adopt all of the suggestions.
First published on BankersOnline.com 10/21/02