Limiting the Definition of Executive Officer in a Bank's Compliance Management - CRCM Exam Preparation

Limiting the Definition of Executive Officer

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How may a bank limit the definition of executive officer?

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A. B. C. D.

B

The term "executive officer" is defined in the regulations of federal banking agencies, including the Federal Reserve, FDIC, and OCC, and generally includes the bank's top management officials such as the CEO, CFO, and other senior executives. However, banks may choose to limit the definition of executive officer for internal purposes or for compliance with specific regulations.

Option A suggests that the bank can limit the definition of executive officer by strictly defining, in writing, the duties and responsibilities of the officers to be excluded from the definition. This means that the bank can specify in writing the duties and responsibilities of officers that do not meet the criteria of an executive officer, and those officers can be excluded from the definition.

Option B suggests that the bank can pass a board of director's resolution setting forth the bank's definition of an executive officer. This means that the board of directors can define who the bank considers to be an executive officer, which could differ from the regulatory definition, for the purpose of the bank's internal policies and procedures.

Option C suggests that the bank can limit the definition of executive officer by requiring that officers to be excluded from the definition not attend loan committee meetings or loan review meetings. This means that the bank can restrict the access of certain officers to sensitive information related to loan decisions, which could limit their role in the decision-making process and therefore their level of authority within the bank.

Option D suggests that the bank can limit the definition of executive officer by limiting the amount of confidential information given to officers to be excluded from the definition. This means that the bank can restrict access to sensitive information to those officers that meet the criteria of an executive officer and have a need to know the information for their job duties.

In summary, a bank may limit the definition of executive officer by specifying in writing the duties and responsibilities of the officers to be excluded, passing a board of director's resolution, restricting access to sensitive information, or limiting attendance at certain meetings. The approach chosen by the bank will depend on the bank's specific circumstances and objectives.