What designated officers are required?

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Question:

What banking positions are required a national bank's board of directors required to appoint? I know that certain regulations require, for example, the appointment of CRA, BSA and Security Officers.

Answer:

I don't know of a definitive list.

To form a bank a CEO is required. Regulatory requirements impose other restrictions as follows.

12 CFR Section 21.2 Designation of security officer.

Within 30 days after the opening of a new bank, the Bank’s board of directors shall designate a security officer who shall have the authority, subject to the approval of the board of directors, for immediately developing and administering a written security program to protect each banking office from robberies, burglaries, and larcenies and to assist in identifying and apprehending persons who commit such acts.

12 CFR Section 21.21 Bank Secrecy Act compliance.
(3) Designate an individual or individuals responsible for coordinating and monitoring daytoday compliance... (it doesn't say officer)
A CRA officer designation is not a requirement. There is also a huge gap between what will be functional and the bare requirements.

First published on BankersOnline.com 3/3/03