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#1568726 - 06/23/11 11:16 AM Who does compliance report to?
c@c Offline
Member

Registered: 03/25/08
Posts: 50
Loc: Georgia
Our bank is in the process of restructuring certain reporting lines. Could anyone please share who your compliance officer and staff reports to?

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#1568755 - 06/23/11 11:36 AM Re: Who does compliance report to? [Re: c@c]
Dani York, CRCM Offline
Power Poster

Registered: 04/13/05
Posts: 2768
Loc: TN
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.

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#1568763 - 06/23/11 11:52 AM Re: Who does compliance report to? [Re: c@c]
AFaquir Offline
Platinum Poster

Registered: 01/12/11
Posts: 763
Loc: Top of the world... and never ...
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!
_________________________
In life, there is a lot less that could get better and a lot more that could get worse.

MBA Fin/MBS HR

My views only!

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#1568956 - 06/23/11 02:14 PM Re: Who does compliance report to? [Re: AFaquir]
renniks Offline
Diamond Poster

Registered: 09/19/03
Posts: 2039
Loc: New England
I am Compliance and BSA Officer. I report to the CEO (dotted line) and to the Audit Committee of the Board (solid line).

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#1568984 - 06/23/11 02:33 PM Re: Who does compliance report to? [Re: renniks]
manimal Offline
Diamond Poster

Registered: 02/26/08
Posts: 1040
Loc: RAWR.
I am the CO and I report to the bank President.
_________________________
Love bites.
But so do I.


-Halestorm

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#1569055 - 06/23/11 03:23 PM Re: Who does compliance report to? [Re: manimal]
Christine81 Offline
Junior Member

Registered: 03/04/11
Posts: 34
I am the Audit and Compliance Officer...I report to the CFO dotted line and the Board of Directors solid line.

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#1569176 - 06/23/11 04:45 PM Re: Who does compliance report to? [Re: Christine81]
ACBbank Offline
Diamond Poster

Registered: 07/26/06
Posts: 2078
Loc: New York City
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.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1569194 - 06/23/11 04:58 PM Re: Who does compliance report to? [Re: ACBbank]
Just Skittles Offline
10K Club

Registered: 09/10/02
Posts: 11406
Loc: KY
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.

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#1569254 - 06/23/11 05:53 PM Re: Who does compliance report to? [Re: Just Skittles]
Just Jay Offline
10K Club

Registered: 10/26/06
Posts: 13304
Loc: Back to reality
Compliance and BSA Officer... report to the EVP/CFO for day to day items, but ultimately to the Board.
_________________________
I'm gonna pop some tags
Only got 20 dolla in my pocket
I, I, I'm hunting, looking for a come up
This is freaking awesome

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#1569443 - 06/24/11 10:07 AM Re: Who does compliance report to? [Re: Just Jay]
DeeQ Offline
10K Club

Registered: 12/04/02
Posts: 40372
Loc: I don't know!
CRA/Compliance: CEO
_________________________
Work is the curse of the drinking classes. - Oscar Wilde

CRCM/CCEP

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#1569906 - 06/24/11 04:21 PM Re: Who does compliance report to? [Re: DeeQ]
fun grandma Offline
Member

Registered: 11/21/08
Posts: 69
Loc: midwest
Compliance/CRA - CEO then board

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#1569920 - 06/24/11 04:34 PM Re: Who does compliance report to? [Re: fun grandma]
AllSmiles Offline
Gold Star

Registered: 02/01/08
Posts: 256
Loc: where the wind comes sweeping
Compliance/BSA - CFO and President with direct access to th Board

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#1570067 - 06/25/11 10:42 PM Re: Who does compliance report to? [Re: AllSmiles]
Bullseye Offline
Platinum Poster

Registered: 01/27/04
Posts: 911
Compliance/CRA reporting to the Chief Operations Officer

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#1570159 - 06/27/11 09:47 AM Re: Who does compliance report to? [Re: Bullseye]
AnnRoy Offline
Platinum Poster

Registered: 06/04/02
Posts: 701
Loc: South
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).
_________________________
CAMS

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#1570225 - 06/27/11 10:33 AM Re: Who does compliance report to? [Re: AnnRoy]
LNBcompliance Offline
New Poster

Registered: 11/05/08
Posts: 1
Loc: KY
I report to the BOD. The BOD does my annual reviews.

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#1570821 - 06/28/11 02:39 PM Re: Who does compliance report to? [Re: renniks]
Jenifa, Oh Jenny Offline
100 Club

Registered: 08/16/10
Posts: 164
Loc: Southwest
Originally Posted By: renniks
I am Compliance and BSA Officer. I report to the CEO (dotted line) and to the Audit Committee of the Board (solid line).


Same for me.
_________________________
Jenny and me was like peas and carrots.
http://www.linkedin.com/in/jenfriesz

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#1575965 - 07/09/11 03:17 PM Re: Who does compliance report to? [Re: Jenifa, Oh Jenny]
R Banker Offline
Power Poster

Registered: 07/03/03
Posts: 2549
Loc: Austin Texas
Compliance and OFAC - report to COO.
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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#1585657 - 07/31/11 02:33 PM Re: Who does compliance report to? [Re: AnnRoy]
becky p Offline
New Poster

Registered: 04/11/08
Posts: 1
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?

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#1588909 - 08/08/11 12:00 PM Re: Who does compliance report to? [Re: becky p]
WonderWoman Offline
Diamond Poster

Registered: 03/07/07
Posts: 1821
Loc: gone fishin'
BSA/CRA/SOX, Internal Audit, & Compliance report to CRO - who then reports to Audit Committee.
_________________________
"I am fairly certain that given a Cape and a nice tiara, I could save the world"

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#1615367 - 10/13/11 12:52 PM Re: Who does compliance report to? [Re: WonderWoman]
Trees Offline
Power Poster

Registered: 04/22/05
Posts: 3347
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.

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#1615688 - 10/13/11 05:32 PM Re: Who does compliance report to? [Re: Trees]
txbkr Offline
Platinum Poster

Registered: 05/21/04
Posts: 507
Loc: TEXAS
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

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#1619207 - 10/24/11 02:48 PM Re: Who does compliance report to? [Re: txbkr]
Welsh Offline
100 Club

Registered: 03/28/11
Posts: 169
Loc: Kansas
I am the CO and report to the President with direct access to the Audit Committee and BOD

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#1619220 - 10/24/11 03:03 PM Re: Who does compliance report to? [Re: Welsh]
R Banker Offline
Power Poster

Registered: 07/03/03
Posts: 2549
Loc: Austin Texas
COO, Audit Committee and BOD
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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#1629755 - 11/17/11 12:51 PM Re: Who does compliance report to? [Re: R Banker]
West Coast Comp Offline
Gold Star

Registered: 06/21/10
Posts: 343
Loc: Lost in the rain.
General Counsel, CEO
_________________________
Where I go there I am. smile

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#1629785 - 11/17/11 01:13 PM Re: Who does compliance report to? [Re: West Coast Comp]
Matt_B Offline
Platinum Poster

Registered: 09/06/11
Posts: 787
Loc: Iowa
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.
_________________________
Just a second, let me sprinkle around some fairy dust and make all the problems go away.

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