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March 24, 2015
Maze of Debit Card Compliance
Brian Crow

March 25, 2015
Appraisals and Evaluations: Performing Internal Compliance Reviews
Eric Collinsworth

March 30, 2015
Cybersecurity: Third Party Resilience – What the FFIEC Wants You to Know
Susan Orr

April 2, 2015
Fair Lending Hot Topics – Don't Get Burned!!
Patricia Cashman

April 7, 2015
Building a BSA Training Program
Deborah Crawford

April 8, 2015
Advertising Compliance
David Dickinson



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

Registered: 03/25/08
Posts: 69
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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Human Resources
#1568755 - 06/23/11 11:36 AM Re: Who does compliance report to? [Re: c@c]
Dani York, CRCM Online
Power Poster

Registered: 04/13/05
Posts: 3385
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.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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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 Online
Diamond Poster

Registered: 09/19/03
Posts: 2128
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: 2207
Loc: Deleted
I am the CO and I report to the bank President.
_________________________
We're all here 'cause we've lost control.

Innerpartysystem

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

Registered: 03/04/11
Posts: 45
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 Online
Power Poster

Registered: 07/26/06
Posts: 2774
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]
Skittles Online
10K Club

Registered: 09/10/02
Posts: 12185
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.
_________________________
The price of discipline is always less than the pain of regret. –Nido Qubein

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

Registered: 10/26/06
Posts: 13768
Loc: Cheeseheadland
Compliance and BSA Officer... report to the EVP/CFO for day to day items, but ultimately to the Board.
_________________________
You are offended by the things I say? Just imagine what I hold back...

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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: 40588
Loc: Back in the hood...
CRA/Compliance: CEO
_________________________
I just finished a meeting that should have been an email. crazy
CRCM/CCEP

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

Registered: 11/21/08
Posts: 86
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: 290
Loc: Mayhem
Compliance/BSA - CFO and President with direct access to th Board
_________________________
CRCM, CAMS

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

Registered: 01/27/04
Posts: 962
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 Online
Platinum Poster

Registered: 06/04/02
Posts: 749
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, CRCM Offline
100 Club

Registered: 08/16/10
Posts: 177
Loc: USA!
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.

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

Registered: 07/03/03
Posts: 2649
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: 2018
Loc: gone fishin'
BSA/CRA/SOX, Internal Audit, & Compliance report to CRO - who then reports to Audit Committee.
_________________________
My opinions are my own, and not that of my employer.

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

Registered: 04/22/05
Posts: 3772
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]
MyKidsMom Offline
Platinum Poster

Registered: 05/21/04
Posts: 580
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: MyKidsMom]
Welsh Offline
100 Club

Registered: 03/28/11
Posts: 214
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: 2649
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: 350
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 Online
Diamond Poster

Registered: 09/06/11
Posts: 1428
Loc: A CU, Where Regs Don't Apply
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.
_________________________
Someone's about to get horned!

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