Required Security Officer Training?

I'm going to Nashville next week to participate in a seminar with security officer trainer David Battle. I had a call from a security officer in Tennessee who said he was reading the ad about the sessions, and in it the Tennessee Bankers Association had stated that "?this seminar qualifies as annual training for security officers as required by the Bank Protection Act."

The security officer wanted to know where the BPA said that.

Like many laws and regulations written by the government, you won't find clear, concise, direct statements like that.
You'll have to see how examiners and security officers got there by reading around the requirements. First, the actual Bank Protection Act doesn't say anything about training. It says that each federal supervisory agency (e.g. FDIC, OCC, FRS, OTS) "?shall promulgate rules establishing minimum standards?with respect to?security devices and procedures?" etc.

Each of the agencies then issued their regulations-most titled something like "Minimum Security Devices and Procedures?"

Each of the regulations say the same thing-in slightly different wording-about training. Among the requirements is this statement: "The security program shall provide for initial and periodic training of officers and employees in their responsibilities under the security program?etc."

The Security Officer is responsible for training others.

Who trains the Security Officer?

The regulation doesn't skip the Security Officer. It says "officers and employees", implying ALL officers.

Therefore, it is the opinion of security experts that the training of the Security Officer should be a part of the requirements of your security program. We think your Board of Directors would agree. If you have written it into your program, you've now covered all officers of your financial institution. The regulations also say the Board of Directors should receive a report at least annually on the implementation, administration and effectiveness of the security program. A Security Officer who has received annual training will have no problem with this part of his or her report.

One last caveat-we've learned through one of our advisors that the OCC and some Federal Reserve regional offices are now starting to check security programs and training, in light of the increased activity in bank robbery.

To be forewarned?

Copyright © 1997 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 7, No. 11, 9/97