Combining Auditor & Security Roles

Question: In several of your workshops, I've heard you and other speakers advise against combining the roles of Auditor and Security Officer, especially when the Security Officer is also the BSA Officer. My bank was criticized by the examiner because I am on the Audit Committee (but not the Bank Auditor) as well as being the Board appointed Security Officer. Is there anything in the regulations that says what you do - that the two positions should be separate. Do you know of any such section in any of the regs?

Answer: As far as I am aware, there is no regulation regarding the separation of the positions you questioned. It is probably a matter of conflict of interest. If the Security Officer/BSA Officer is also auditing his work it's a problem. If being on the audit committee is only in the capacity of advising on matters such as policy and procedures but not actually conducting the audits then the Security/BSA Officer could be part of the committee.

Our thanks to Thomas Fleming, Educational Activities Specialist, Office of Thrift Supervision

Copyright © 2001 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 11, No. 11, 11/01