New Emphasis on BPA by Examiners?

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Question:

I have attended several security workshops where Dana Turner was the presenter. At one of the seminars, he referenced training examiners on conducting exams related to compliance with the Bank Protection Act and that there was to be an increased focus on this. This was about 18 - 24 months ago and I've not heard anything more, so I wondered if there was any new information on this?

Answer:

The agencies haven't issued any kind of a dire warning -- regional heads of those agencies may choose to make this a focus but they're not going to tell anyone about it first. I know of some agencies that have made this a regional priority and others who don't see this as an issue. I wish I had a better answer for you. But consider this. Even if the agencies don't look, your institution's compliance (or lack of) with basic, elementary security processes will likely become an issue in any legal action and presented to a jury. Your non-compliance may be used to demonstrate that you didn't exercise reasonable and prudent care in conducting your business activities and a jury may find for the person who sues you.

There is more to compliance with these rules than just appeasing examiners. The root of the matter is you have to be pleased with your efforts and confident with the results.

First published on BankersOnline.com 8/21/06