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#1568726 - 06/23/11 03:16 PM Who does compliance report to?
c@c Offline
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Joined: Mar 2008
Posts: 120
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 03:36 PM Re: Who does compliance report to? c@c
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
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 03:52 PM Re: Who does compliance report to? c@c
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
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!
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#1568956 - 06/23/11 06:14 PM Re: Who does compliance report to? AFaquir
renniks Offline
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renniks
Joined: Sep 2003
Posts: 2,162
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 06:33 PM Re: Who does compliance report to? renniks
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
I am the CO and I report to the bank President.
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#1569055 - 06/23/11 07:23 PM Re: Who does compliance report to? manimal
Christine81 Offline
Member
Joined: Mar 2011
Posts: 78
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 08:45 PM Re: Who does compliance report to? Christine81
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
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.
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#1569194 - 06/23/11 08:58 PM Re: Who does compliance report to? ACBbank
Skittles Offline
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Skittles
Joined: Sep 2002
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TN
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 09:53 PM Re: Who does compliance report to? Skittles
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
Compliance and BSA Officer... report to the EVP/CFO for day to day items, but ultimately to the Board.
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#1569443 - 06/24/11 02:07 PM Re: Who does compliance report to? #Just Jay
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
CRA/Compliance: CEO
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#1569906 - 06/24/11 08:21 PM Re: Who does compliance report to? Retired DQ
fun grandma Offline
Member
fun grandma
Joined: Nov 2008
Posts: 91
midwest
Compliance/CRA - CEO then board

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#1569920 - 06/24/11 08:34 PM Re: Who does compliance report to? fun grandma
AllSmiles Offline
Gold Star
Joined: Feb 2008
Posts: 290
Mayhem
Compliance/BSA - CFO and President with direct access to th Board
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CRCM, CAMS

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#1570067 - 06/26/11 02:42 AM Re: Who does compliance report to? AllSmiles
Bullseye Offline
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Bullseye
Joined: Jan 2004
Posts: 968
Compliance/CRA reporting to the Chief Operations Officer

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#1570159 - 06/27/11 01:47 PM Re: Who does compliance report to? Bullseye
AnnRoy Offline
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AnnRoy
Joined: Jun 2002
Posts: 771
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).
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#1570225 - 06/27/11 02:33 PM Re: Who does compliance report to? AnnRoy
LNBcompliance Offline
New Poster
Joined: Nov 2008
Posts: 3
KY
I report to the BOD. The BOD does my annual reviews.
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#1570821 - 06/28/11 06:39 PM Re: Who does compliance report to? renniks
Y'all Comply Offline
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Y'all Comply
Joined: Aug 2010
Posts: 214
Land of Pears
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 07:17 PM Re: Who does compliance report to? Y'all Comply
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Compliance and OFAC - report to COO.
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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 06:33 PM Re: Who does compliance report to? AnnRoy
becky p Offline
New Poster
Joined: Apr 2008
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 04:00 PM Re: Who does compliance report to? becky p
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
BSA/CRA/SOX, Internal Audit, & Compliance report to CRO - who then reports to Audit Committee.
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My opinions are my own, and not that of my employer.

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#1615367 - 10/13/11 04:52 PM Re: Who does compliance report to? WonderWoman
Trees Offline
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Joined: Apr 2005
Posts: 4,013
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 09:32 PM Re: Who does compliance report to? Trees
MyKidsMom Offline
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MyKidsMom
Joined: May 2004
Posts: 641
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 06:48 PM Re: Who does compliance report to? MyKidsMom
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 335
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 07:03 PM Re: Who does compliance report to? Patricia
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
COO, Audit Committee and BOD
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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 05:51 PM Re: Who does compliance report to? RBanker
West Coast Comp Offline
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West Coast Comp
Joined: Jun 2010
Posts: 350
Lost in the rain.
General Counsel, CEO
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#1629785 - 11/17/11 06:13 PM Re: Who does compliance report to? West Coast Comp
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
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.
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