Answer:
Answer from Ken: Generally, specific officer positions are required by your chartering agency, not other laws or regulations. If you are a state charted institution, check with your state's department of financial institutions as they vary from state to state.As far as "compliance" is concerned, I only know of two positions required by law or regulation, the Security Officer and the BSA Officer. CRA Officer might be another.
Answer:
Answer from Andy: Officer positions are very much like policies. There are only a few that are required, but there are many that are needed. That is, you may not have to designate a specific person with a title and responsibilities that go with it, but you certainly need persons with authority performing those specific tasks. They may have other titles as well as few people do just one job in many banks. When your examiner wants to know who does a specific job, and that job is required, you need an answer. Banks also find it easier to delegate tasks when they have a full cadre of officers designated for tasks such as compliance, CRA, Privacy, SCRA and more. Like policies, the needs will depend on your bank, what it does, where and how often.
First published on BankersOnline.com 1/9/12
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