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Security Officer Designation and Training

To fill the role of security officer, our bank may at times arbitrarily appoint an employee from a branch location as the branch security officer. This employee could be a teller, a loan officer, a new accounts rep, or a loan officer who has not received any type of security officer training. I am concerned that the bank is putting employees into a position that they don’t really want to be in and are ill-equipped to handle. I was recently hired as the Senior Security Officer for the entire bank and would like to recommend that the bank discontinue this practice. Is this a normal practice at other banks and, if so, what type of training do you suggest we provide these “newly elected” security officers?

by Banker's Hotline

Answer: Congratulations on your new position! We certainly understand your concern with putting employees into a security role without proper training. While we can’t speak for what “most banks” do, it’s not uncommon for bank employees to wear different hats within the bank – especially when budget cuts and bank mergers come into play.

With that being said, anyone who is placed in a security officer role should be armed with proper training. The guidelines for the designation of a security officer in the FFIEC IT Handbook, 12 CFR 326, subpart A: Minimum Security Procedures, are as follows:

§ 326.3 Security program.
(a) Contents of security program. The security program shall:
(1) Establish procedures for opening and closing for business and for the safekeeping of all currency, negotiable securities, and similar valuables at all times;
(2) Establish procedures that will assist in identifying persons committing crimes against the institution and that will preserve evidence that may aid in their identification and prosecution; such procedures may include, but are not limited to:
(i) Retaining a record of any robbery, burglary, or larceny committed against the institution;
(ii) Maintaining a camera that records activity in the banking office; and
(iii) Using identification devices, such as prerecorded serial-numbered bills, or chemical and electronic devices;
(3) Provide for initial and periodic training of officers and employees in their responsibilities under the security program and in proper employee conduct during and after a robbery, burglar or larceny; and
(4) Provide for selecting, testing, operating and maintaining appropriate security devices, as specified in paragraph (b) of this section.

For 25 years, Bankers’ Hotline has offered security officer training for new and seasoned security officers at our annual Bank Security Conference. Now in it’s 27th year, the conference is held via remote streaming (perfect for training an entire group of staff members). Get all the details and register here!

This Q&A originally appeared in Bankers' Hotline. For more information, sample issues, and to subscribe, click here or email

First published on 09/05/2021

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