Memo To Security Officers
There were so many of our subscribers who requested samples of the Security Program and Security Report (25 percent of our subscribers!) that we hurried to get them in the mail to you. We'd like to add a word to the correspondence sent with the samples.
The Bank Protection Act and the resulting regulations very specifically state the fact that they address "robberies, burglaries and larcenies." Such things as internal fraud and controls, new account procedures, disaster recovery, and compliance in other areas are not part of the security program that is to be prepared and approved by the board of directors.
But there are other things you will want to include in your security program to make it complete for each of your banking offices. They aren't necessary for meeting the requirements of Bank Protection, but they are important for your security manual to be complete. You will want to add sections on:
Counterfeits
Check cashing guidelines
Identification
New account procedures
Endorsements
Teller cashing limits
Internal controls
Robbery employee assignments
In your training, (but maybe not in your manual-too many changes to update too often) you will want to touch on:
Bank Secrecy
Expedited Funds
Community Reinvestment
Financial Privacy
Service of summons
The importance of TINs
Safe deposit procedures
Fair Credit
We have already covered some of these in past issues on the training page of the BANKERS' HOTLINE, and will continue to address these topics in the future. In the meantime, don't overlook these areas when you are preparing your security program.
Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 7, 8/91