Who does compliance report to?

Our bank is in the process of restructuring certain reporting lines. Could anyone please share who your compliance officer and staff reports to?

I'm the BSA Officer and the CO. I report to the President.

In a past life, when doing only compliance, I reported to the Senior Credit Officer. IMO, this is a huge conflict of interest.

Generally in my experience, Compliance should report to either a) Chief Risk (Management) Officer or b) President/CEO... They should also always have an additional line reporting directly to the Board of Directors.

Compliance is an officer position and as such (even without titles like VP, EVP, or SVP) should have direct reporting lines to the highest level of management or at least an appropriately titled and trained C-suite executive who's primary function is the protection of the bank (hence the CRO)... if the CRO has the reporting responsiblity of compliance issues above the CEO and directly to the board.

Otherwise the CEO and the Board is who the Compliance Officer should report to.

Cheers!

I am Compliance and BSA Officer. I report to the CEO (dotted line) and to the Audit Committee of the Board (solid line).

I am the CO and I report to the bank President.

I am the Audit and Compliance Officer...I report to the CFO dotted line and the Board of Directors solid line.

I'm the BSA/CRA Officer and I report directly to the CO, who in turn reports to the President. I also have direct access to the Board.

I have worked in 4 different banks as a CO and have reported to:

The Internal Auditor
The CFO
The COO

However, in all cases this was for daily routines and administrative. Technically I always reported to the Audit Committee.

Compliance and BSA Officer... report to the EVP/CFO for day to day items, but ultimately to the Board.

CRA/Compliance: CEO

Compliance/CRA - CEO then board

Compliance/BSA - CFO and President with direct access to th Board

Compliance/CRA reporting to the Chief Operations Officer

Our CO reports to the Chief Risk Officer (CRO) who heads up the Risk Mgmt Division. Under Risk Mgmt are the following depts - Internal Audit, BSA, Compliance, Operational Risk, Loan Processing and the Chief Credit Officer who oversees the following functions -Loan Review, Special Assets, Credit Risk Mgmt, Credit Analysts and Business/Consumer Lending Services (underwriting).

I report to the BOD. The BOD does my annual reviews.

Same for me.

Compliance and OFAC - report to COO.

AnnRoy, I am wondering who your CRO reports to? Also, when you mention Loan Processing, is under CCO, does that include the document processing or just the underwriting, analysis, review components?

BSA/CRA/SOX, Internal Audit, & Compliance report to CRO - who then reports to Audit Committee.

Recent examination said no to the C.O.O. as this person was responsible for line activities. Potential conflict of interest, so they said.

So we created a Risk officer....and I report to that person....in a dotted fashion but to the board as well.

Trees - What sort of background does your risk officer have? We are in the process of creating such a position and I'm doing some research

I am the CO and report to the President with direct access to the Audit Committee and BOD

COO, Audit Committee and BOD

General Counsel, CEO

Our CFO/Executive VP, that's it at this point. I'm hoping when I've proved myself somewhat educated that I'll have access to the board directly...but have been given no indication of that.

CO --->CFO operationally, report to the Board
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CEO

I think it depends on your role in the organization. If you are a true compliance officer, where you assess risk, write policies, do QA reviews and provide help to departments you can really report to anyone.

If you are serving as a formal audit function there is only one area you should report to, and that is the BOD. If you are to be independent you should never be reporting to an internal employee. Additionally, if you are a true auditor, you are serving as a representative of the board and only the board.