Some of our people are hearing that the regulators are suggesting that the BSA Officer should be independent of management. The annual test, of course, should be independent, but I've never heard it recommended that the BSA Officer be "independent"...

Anyone else hearing the same thing?

I was the BSA Officer up until last month. And yes, what you are hearing is true. The recommendation is that the BSA Officer be segregated from daily operational duties that would include CTR monitoring and such. In addition, with an increased focus on AML it is felt that someone with a more investigative background be the BSA Officer.

Well, I audit our BSA officer, and as long as I am independent of his functions, that was sufficient for my examiners.

No question. Better to have you report to the full board or a board committee. They will criticize anything else!