Since officer designations differ so greatly from one institution to another, examiners are more concerned with the job function than they are with title. As long as you have enough influence and/or authority to deal with department managers who might be at the VP level or higher, then you are okay from a regulator standpoint.

I don't think it specifies "senior officer"; it specifies that it has to be someone who has sufficient authority to be the BSA officer.

It suggests that the person be a senior level. That's what happens when I read too fast. Missed that one key word. Thanks!!!!

I do that all of the time.

You all are officers at least. The BSA officer retired. I am the loan compliance geek- no officer title but they dumped BSA and retail compliance on me (no raise either). There is no senior officer for me to report to except the President he is my direct supervisor. Our assets are just under 180 million. If you read the job description of the person who retired I am her plus 10 other hats. My concern is that instead of elivating the position we downspouted it to Manager level. That cannot be good. Can anyone direct me to the infomation that requires an officer level for BSA? Our regulator is FDIC. Help appreciated.

From the FFIEC BSA/AML Examination Manual, page 27:

The bank’s board of directors must designate a qualified employee to serve as the BSA compliance officer.31 The BSA compliance officer is responsible for coordinating and monitoring day-to-day BSA/AML compliance. The BSA compliance officer is also charged with managing all aspects of the BSA/AML compliance program and with managing the bank’s adherence to the BSA and its implementing regulations; however, the board of directors is ultimately responsible for the bank’s BSA/AML compliance.

While the title of the individual responsible for overall BSA/AML compliance is not important, his or her level of authority and responsibility within the bank is critical. The BSA compliance officer may delegate BSA/AML duties to other employees, but the officer should be responsible for overall BSA/AML compliance. The board of directors is responsible for ensuring that the BSA compliance officer has sufficient authority and resources (monetary, physical, and personnel) to administer an effective BSA/AML compliance program based on the bank’s risk profile.

continued.........

The appointment of a BSA compliance officer is not sufficient to meet the regulatory requirement if that person does not have the expertise, authority, or time to satisfactorily complete the job.

Also, you will find guidance in 12 CFR 326.8 stating that the bank must designate one or persons to coordinate and monitor day-to-day compliance

From above post:
"The BSA compliance officer may delegate BSA/AML duties to other employees, but the officer should be responsible for overall BSA/AML compliance." Perhaps you need to look at all your responsibilities and see what can be delegated to others - either reporting to you or in other areas. Also suggest that you look at your scope of reviews and frequency regarding yourloan compliance responsibilities. Can they be narrowed?
I worked at a 250mm bank where I was BSA, Compliance, Privacy, Loan Review and Audit and was able to manage they job by asking myself what is the risk and does the level of risk warrant the time I'm taking to review it. Focus on controls, processes and procedures.

Thanks everyone for your valuable input. I believe BSA is a big job and deserves more of my attention. I only wish I could dump some of the other hats but no help in sight for now. Thankfully we are still small enough for it to be somewhat managable

Our bank has a BSA officer who is also a CO. We also have an internal auditor doing compliance review. We think a BSA officer could not be an CO if there is no independent audit function side by side with the compliance function. As far as there is an "internal audit" function, it should not be a concern. We just had a BSA examination and the results were impressive. The examiners indicated that our audit function is good.

I am the CO, BSA Officer, and OFAC Officer for our billion dollar bank, and I am only a 'banking officer'. So I guess it doesn't really matter what level of officer you are...?

Compare the "old" description from the FDIC handbook:

To meet the minimum requirement, each financial institution must designate a senior official within the organization to be responsible for overall BSA compliance. Other individuals in each office, department or regional headquarters should be given the responsibility for day-to-day compliance. The senior official in charge of BSA compliance should be in a position, and have the authority, to make and enforce policies. This is not intended to require that the BSA administrator be an "executive officer" under the Federal Reserve Board's Regulation O.

To the "new" (cited above):

While the title of the individual responsible for overall BSA/AML compliance is not important, his or her level of authority and responsibility within the bank is critical. The BSA compliance officer may delegate BSA/AML duties to other employees, but the officer should be responsible for overall BSA/AML compliance. The board of directors is responsible for ensuring that the BSA compliance officer has sufficient authority and resources (monetary, physical, and personnel) to administer an effective BSA/AML compliance program based on the bank’s risk profile.

Note, the reference to "senior official" does not appear in the current version, nor does the "ability to make and enforce policies" (the true emblem of the Big Kahuna). While the examination procedures are not law or regulation and some attempts to "interpret" them can be a little silly, it appears they have backed off of the suggestion that the BSA officer must be a mover and shaker within the organization.

In my experience, they only cited this criticism when things were not getting done, edicts were being ignored, etc. or when BSA compliance was clearly nothing more than a clerical function. If there is philosophical adjustment reflected above, it is probably only made in favor of practicality.

Kaybee,
I'm not suggesting that they are backing off in general. By adding the reference to the board being ultimately responsible, they obviously are not.

Anon 410098's question was about the sufficiency of his title and my response was: "...it appears they have backed off of the suggestion that the BSA officer must be a mover and shaker within the organization." Sorry if that wasn't clear.