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A Nice Arrangement
Keeping up-to-date with the Bank Secrecy Act was a difficult task for the compliance officer, for she had numerous other duties as well. She was lucky, though, that one of her staff had attended all kinds of seminars and meetings about BSA and was extremely knowledgeable in it. She handled all BSA work for the compliance officer.
It was a double blow for the compliance officer when this staff member not only planned to go on maternity leave. But also, worse yet, she was not interested in coming back to work full time after she had the baby, and planned on looking for a part-time job.
The compliance officer became innovative. She hired back her Bank Secrecy expert almost the week after she left-on a part-time basis.
She comes in one day a week-on Wednesday. On that day she catches up on all the reading that has come in regarding BSA and summarizes it for the rest of the staff. She reviews, corrects and sends out all the CTRs that have been done since last Wednesday, and answers any questions anyone has about BSA reporting. The financial institution has no exemptions, so there is no daily bookkeeping checking necessary.
She makes any phone calls necessary, and does investigations and research. BANKERS' HOTLINE learned of her working arrangement when she called us with a question about a suspicious transaction. She is available by phone at home the rest of the week-and doesn't mind the occasional call she gets there.
Once each month she comes for a few hours and spends time giving presentations and up-dates at each of the four branch meetings that are held with all the tellers, and branch personnel. She collects the monthly $3,000 to $10,000 log while she's in each office.
Once each quarter she attends an officer's meeting and makes her report on activity in the Bank Secrecy area.
The compliance officer is still on the job for emergencies. And of course she is still ultimately responsible for the financial institution being in compliance. But she is kept up-to-date through the part-timer's research and communications. And she is relieved of the stress of the day-to-day details and reading.
A nice arrangement!
Copyright © 1992 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 3, No. 4, 8/92
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