Has anyone heard or been told that the BSA Officer must be "reaffirmed" by the Board every year? A comment was made from a bank examiner (not during a bank exam) that the board should re-appoint the BSA Officer annually. I have never seen this in anything that i have read, but was curious if anyone else has heard this before.

Off the cuff--

I am not aware of any regulatory citation for an annual re-affirmation.

I think it more stems from the operation of the bank as a corporate entity where a corporation has to re-appoint its officers to serve another one-year term.

The only requirement that I am aware of is that you have to have one appointed that basically knows how to do the job and carry out the functions of the job. No annual requirement. Check the BSA FFIEC manaual...page 32

Smash is right, it would depend on your organizational documents and whether or not officers are appointed for an indefinite period or have to be appointd annually. It has nothing to do with BSA regulations.

Our board reaffirms all officers every year. I'm not sure that it is because of any regulation though--it's just our standard operating procedure.

Ditto Bethel.