from GARP:

In order to be certified as a Financial Risk Manager (FRM) and be able to use the FRM acronym after your name, the following is required:

    A passing score on both Part I and Part II of the FRM Exam
    A minimum of two years professional full-time work experience in the area of financial risk management or another related field including, but not limited to: trading, portfolio management, faculty academic, industry research, economics, auditing, risk consulting, and/or risk technology.

and the qualifying job titles in commercial bank:
Commercial Bank
       
Assistant Banking Officer; Assistant Relationship Manager; Associate Director - Structured Credit Management; Assistant Vice President - Group Investment Banking; Audit Manager; Balance Sheet Manager; Banking Associate; Bond Dealer; Business Analyst; Business Engineer; Business Project Manager; Chief Accountant; Chief Analyst; Chief Auditor; Client Manager; Compliance Officer; Counterparty Risk Analyst; Credit Risk Analyst; Credit Risk Manager; Credit Risk Models Developer; Deputy Manager - Credit Division; Derivatives Verification Officer; Economic Analyst; Executive Director - Risk Integration and Measurement; Finance & Compliance Manager; Financial Analyst; Financial Consultant; Financial Controller; Fixed Income Analyst; Functional Audit Director; FX Manager; FX Option Trader; Head of Audit; Head of Equities; Head of Risk Capital and Stress Testing; Internal Auditor; Junior Risk Manager; Market Risk Analyst - Planning and Finance; Money Market Trader; Operational Risk Manager; Portfolio Manager; Portfolio Risk Advisor; Product Manager; Project Director; Quantitative Analyst; Research Analyst; Risk Modeling Manager; Segment Analyst; Senior Consultant; Senior Credit Analyst; Senior Development Consultant; Senior Financial Analyst; Senior Financial Compliance Officer; Senior Investment Manager; Senior Modeling Analyst; Senior Risk Analyst; Senior Risk Consultant; Sr. Finance Product Analyst; Statistician; Stock Trader; Strategic Planner; Transaction Monitoring Analyst; Treasury Analyst; Treasury Control Manager; Treasury Risk Accountant; Vice President - Head of Credit Risk Management

So I'm pretty sure u could find a qualifying title here, like whatever manager or analyst, thing is u gotta emphasize to GARP that 50% or more of your job responsibility or daily work is related risk management. shouldn't be an issue, imo.

您好，我是奋斗在银行最前线的柜员，我该怎样些我的Position/Title呢