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#1209239 - 06/29/09 02:45 PM Internal auditor & compliance officer
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Let me begin by saying that we are a very small bank (less than $150 million) with very few employees. I currently hold the title of internal auditor and compliance officer. Our regulators have raised concerns about me holding both titles. They cite independence issues (ie. - I could be auditing my own work).

I conduct audit and compliance risk assessments, create audit/review schedules, and conduct the reviews. We do engage an third-party consultant to conduct some independent reviews each year. As far as operations is concerned, I am independent from daily processes. On the compliance side, I do assist in creating policies and devising processes, consulting, and training.

Management is considering moving the compliance officer title to another individual (with limited compliance background), but not truly changing anyone's daily responsibilities - meaning I'd still be the one to handle all compliance issues as they arise. It seems like a smoke screen to appease the regulators. We surely won't be hiring another person so we can have a seperate compliance officer and a seperate auditor.

Any ideas or suggestions on what we can do or how we can respond to the regulators?

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Audit
#1209301 - 06/29/09 03:44 PM Re: Internal auditor & compliance officer AuditorK
Life of Riley Offline
Gold Star
Joined: Sep 2006
Posts: 388
In a pineapple under the sea
AuditorK, my situation and FI size was pretty similar to yours. Managment reassigned the Compliance Officer title to another employee who also had limited compliance background. I assist with research and provide guidance from time to time with the compliance function i.e. policies, processes and training. Our regulators seem to like this set-up much better.
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#1209498 - 06/29/09 07:10 PM Re: Internal auditor & compliance officer Life of Riley
WV Banker Offline
New Poster
Joined: Jan 2005
Posts: 11
West Virginia
I am also in a similar situation. My bank is a little larger - nearly $200 million. I am the auditor and compliance officer. However, my compliance role is limited to consulting and compliance auditing. The individual department supervisors are responsible for ensuring compliance in their areas, including revising/creating policies & procedures when regulations change. I keep up with all changes and monitor management's progress on implementing changes. I advise management when changes are coming up, what they entail, when they are effective, etc. I share my resources with them as needed (i.e. - passing on FILs, sample policies, etc.). I also recommend best practices that I've seen work for other banks in my past lives. Our examiners are okay with this since I remain independent in both compliance and auditing.

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#1213164 - 07/06/09 08:48 PM Re: Internal auditor & compliance officer WV Banker
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
AS long as you're not auditing your specific areas of responsibility, I don't see why it's an issue. I wear both hats and do internal audits all the time. The only one we truly outsource is BSA audit b/c I'm also the BSA officer.

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