Heads Up!

When I first learned of the changes to the Security Regulations, I started talking about the related problems for security professionals in my seminars and after dinner speeches. I was astonished at the apathy exhibited by security officers. Instead of a knee-jerk reaction, it was a shrug-of-the-shoulders type of, "Well, what will be, will be" attitude.

When the final regulations came out, they seemed simple enough. Dangerous, but simple. And security officers set about doing what has to be done. And watching over their shoulders for incoming missiles.

In an effort to help, we reviewed many security programs and board reports and put samples together to assist security officers in their efforts.

Because we wanted the security program and board of directors reports to be as "examiner-proof" as possible, we sent them to quite a few officers and friends in government regulatory and examining agencies to get their opinions and input. When we got the evaluations back, we understand even more the frustrations possible in today's banking industry.

Just to give you an idea of the scope of the comments-one officer said the fourteen pages was a good start, but wasn't detailed or complete enough to satisfy his translation of the requirements. He felt a great deal more needed to be included in both the security program and the report to the board of directors.

Another officer-same job, same rank, same agency, different city-said the fourteen pages was entirely too long. In his opinion neither the program nor the report should be over one page long-best if only four short paragraphs each.

One officer complimented us for having picked up on the fact that the regulations require a different, if similar, program for each banking office-especially in the security program covering opening, closing, vault procedures, etc.

Another came back with the opinion that we had misinterpreted the meaning of the term "banking office"-that "each banking office" meant "each institution". Therefore all that is required is one program for the entire institution, no matter how many offices or branches it has.

Which is correct? Which will your examiner be looking for? Which will keep you out of trouble? Who knows? You'll just have to do your best to second guess the requirements.

We will continue to check material and information with many sources, and will pass on to you the results of our research. And we'll probably continue to be opinionated. But you can understand why our legal advisors insist on a disclaimer on each copy of the HOTLINE.

Like you, we keep looking over our shoulder.

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 7, 8/91