Written Security Program and Board of Directors

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Question:

Does the written Security Program for a bank have to be approved by the Board of Directors? If so, do subsequent updates also have to be approved by the board? This is not to be confused with the regular reports to the board about the status of the bank relating to the program.

Answer:

While it does not state explicitly in the regulations that the security program must be approved by the board, it does state that the appointment of the security office with authority to administer a security program is required of the board. It also stipulates minimum requirements for the security program. I've always taken that as an implicit requirement that the board also approve the security program and have done so. I've always had the board re-affirm that program at least annually and approve any changes to the program.

First published on BankersOnline.com 5/30/11