Titles assigned to various positions differ from bank to bank making it impossible to determine if individuals meet the criteria by virtue of their title alone. Within an organization, “bank signing officer” may include individuals who are both qualified and unqualified to act as guarantor. The term has no clear universal definition. By keeping the guarantor categories to manageable proportions, the Passport Office is able to verify guarantor qualifications at minimal cost without disrupting rapid service.
There was no supporting documentation considered, however, “bank signing officer” is not clearly defined. When the name of a signing officer does not appear on the association’s membership list, the Passport Office is unable to verify his or her qualifications. Because there is no association or official membership list that covers all types of bank signing officers, the decision was made, effective immediately, to remove the category.