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#410772 - 08/19/05 02:44 PM In a pickle
Anonymous
Unregistered

I need some advice on a situation. I'm the internal auditor at a community bank. I'm expected to do the BSA independant audits but am haveing a problem staying independant. The BSA officer is also the Head Teller and the teller turnover here is mind boggleing. She is always so busy with training and helping new tellers that the BSA program is suffering, and so is her stress level. I have a lot of respect for her as a person and how hard she tries to keep things under control, but she NEEDs help. The CFO is her supervisor and is equally bogged down, so he understands her stress, but can't help. No one else understands BSA here except me, so, I'm a softy and end up helping her. I've done the risk assesment, updated policy, given teller trianing, iniciated a CIP compliance program, etc. I'm losing my independance, but I just don't have the heart to rip into the BSA program in my reports because I know how hard she is working. The other problem is the Board, they are fire happy. The CFO and CEO have discouraged me from mentioning anything to the board about this because they are affraid of reprocussions. Also, in our last exam, the OCC gave our program a favorable report, which I personally feel is because they didn't look at it very close, but the CFO and CEO point to that as proof that everything is fine and I didn't need to make any recommendations in my reports.

So, any insights?

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#410773 - 08/19/05 03:03 PM Re: In a pickle
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Find another job! Other than that...what size bank are you? If you are small, you might get away with the loss of independce to a point. If you are large enuf, the examiner's will critize this and expect/recommend staff expansion. You might try showing your superiors penalties imposed recently as a reason for your justified concern. BSA is no laughing matter. Even in well run insitutions, this is one area you just can't seem to do enuf in anymore to please anyone!
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#410774 - 08/19/05 03:41 PM Re: In a pickle
Anonymous
Unregistered

we are a 3 branch 100 million dollar bank. I doubt that the CEO or the board would approve staff expantion, they think the fact that they have to "monkey around" with BSA stuff ridiculous and anoining. I can't afford a job change right now.

How independant do I have to be in this size of institution? Are there some things I can help with and others that are deffinate "no,no's" ? Where do I draw the line?

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#410775 - 08/19/05 03:42 PM Re: In a pickle
Anonymous
Unregistered

Have a private chat with the BSA Officer and tell her you need to do your job; namely, to perform an annual independent BSA audit and submit a report to the Audit Committee that recommends the bank needs a dedicated, experienced, independent BSA Officer and the bank is playing Russian roulette with the OCC. If you do not wish to perform this audit, engage an outside audit vendor do do it for you and tell them about your concerns so they will put it in their report. Your CEO, CFO and Board need to wake up and smell the coffee! BSA compliance is not to be taken lightly. Print some BSA consent orders of banks in your area off your regulator's website and discuss them with your Board, emphasizing the points in the reports that your bank is also vulnerable (BSA Officer independence, BSA training, policies and procedures, Board involvement, etc).
Good luck.

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#410776 - 08/19/05 03:42 PM Re: In a pickle
Anonymous
Unregistered

sorry, not logged in, the last post was Pixiesprite.

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#410777 - 08/19/05 04:02 PM Re: In a pickle
Anonymous
Unregistered

actually it was the one before last, someone has fast fingers

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#410778 - 08/19/05 04:22 PM Re: In a pickle
Anonymous
Unregistered

Want to hear somthing funny, I just found out that the Senior Lender is "no longer working here" and no one knows why. See what I mean about fire happy?

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#410779 - 08/19/05 05:05 PM Re: In a pickle
berico Offline
Gold Star
Joined: Jun 2004
Posts: 290
California
Like an internal auditor, I report to the Board of Diectors as General Counsel. I would not be able to continue in my job if I felt that management could dictate how and when I report findings to the Board.

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#410780 - 08/19/05 09:26 PM Re: In a pickle
Anonymous
Unregistered


How independant do I have to be in this size of institution? Are there some things I can help with and others that are deffinate "no,no's" ? Where do I draw the line?




Anyone want to take a stab at this one?

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#410781 - 08/20/05 12:19 AM Re: In a pickle
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I think that in smaller institutions, the regulators are going to allow a little more latitude on the independence issue. I think it is wise for banks like yours to seek outside assistance, but realistically that is not always possible depending on management attitudes. I say go forward - continue to assist where you can - try to get line management to assume more of the duties - continue to voice your concerns to management and work on a plan to get yourself more and more independent and wait and see what the regulators have to say. If your institution is growing, the regulators will eventually force management's hand on this issue anyway.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#410782 - 08/20/05 02:12 PM Re: In a pickle
Anonymous
Unregistered

Thanks, what I would love is if they hired outside for BSA audits and let me assist the BSA officer with compliance. I've been shot down on this because they pay me a lot less than they would have to pay to go outside. But I think I'll keep bringing this up. Also, my report is due in October and the OCC is coming in September, so I'm hoping they will see the situation from my workpapers and then they can be the ones to put pressure on managment. Here's hopeing neither me or the BSA officer end up as collateral damage.

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#410783 - 08/22/05 03:36 PM Re: In a pickle
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
PS...When our bank was that size, I was the Auditor, Compliance Office, Security Officer and BSA officer and whatever else I might have forgotten. At that time we were an FDIC bank. I believe as we approaced 500m, the examiner's said..."wait a minute, you are stretched WAY to thin...something's gotta give". This was expressed to me and TOLD to management, basically. We are now right at 1B, I am the Compliance Officer, I manage compliance. We have an Internal Audit Staff (fairly large, IMHO) who has recently taken over compliance audits, a BSA staff that is currently being exanded, and a security officer. Things have to change as you grow, but you can get away with a LOT when you are small...just make sure you have all ducks in the best row you can get them and you and the BSA officer should be ok...the examiner's should pretty much look out for you before it becomes unmanageable.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#410784 - 08/22/05 08:56 PM Re: In a pickle
Anonymous
Unregistered

Hey, I just got the okay to officially assist the BSA officer and rely on external auditors for the annual audit!

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