Security Officer Reporting Structure

Question:

I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.

Answer:

Examiners have no requirement as to who you should report to and there's no industry-standard that I can cite. You might search BankersOnline.com's threads for this topic and see how your peers have treated it. I recommend that you report to a Security Committee that's appointed by -- and reports to -- your Board of Directors. Ideally, you chair this committee and the members are typically, at least:

Security Officer;
Board member;
President, CEO or designate;
Legal counsel;
Audit manager;
Compliance manager
Human Resources manager; and
Retail Operations manager.

Other persons may be made part of this committee depending upon the situation (e.g., facilities, bookkeeping or lending).

First published on BankersOnline.com 3/31/08