How many security officers, internal auditors, BSA/OFAC/AML officers, compliance officers does your bank have and what is the asset size? Are these positions shared by many people or do you have 1 or 2 employees who cover all of this? We are looking to staff accordingly and are a bank with 250M in assets.

We are 2.4 billion -

SVP Internal Audit
2 auditors (1 doubles as SOX auditor & security officer)
2 loan review
1 compliance officer
1 CRA officer
3 regional compliance specialists
1 bsa officer
1 fraud investigator
2 BSA specialists

We are $600 million and have:

2 auditors
1 security officer
1 Compliance/BSA/OFAC/AML/CRA Officer

We are $210 Million and have:

1 compliance officer/internal auditor <me>
1 BSA Officer
1 Security Officer

Now the BSA Officer is also our COO so she had many other duties. Also, the Security Officer has many other duties, also. The BSA Officer has an assistant who helps with the BSA duties.

This exercise in futility happens about 4 times a year in these threads. If you would like to review this type of meaningless data, I would suggest doing a search. Asking about the size of staff based on asset size is like asking how big of a fork do I need to eat this bowl of soup.

You perform your risk assessments, determine your risks, and staff appropriately. Going to senior management an saying the average bank at our size has 12 people in these positions and we only have 10 - we need two more - is a poor argument. And if that is not where you are headed, then where? I have seen the same size banks (asset size wise) with 1/2 or double the staff size in these positions purely because of the risk profile of the organization.

Randy, I agree that the argument "but other banks our size have this many people" is a poor argument all by itself. HOWEVER, management making the decisions often want to know about what their peers are doing. It would be nice if the "pure" reasons were all that were needed to obtain additional staffing, but it just doesn't work that way when dealing with senior management. I've had to justify why we have 4 folks in BSA - I can tell them all day long the amount of work these folks do and our products/customer base, but for them to hear that other banks have larger numbers helps to keep them from cutting staff in critical areas.

Walden - been there and done that - so I do not disagree. However, a random poll on the BOL threads is not going to do much for support. I would recommend that you team up with a peer bank - similar geographic area - similar customer base - and have a discussion with them. Blind polls are not going to take into consideration a lot of the risk factors that you need to really consider to make a rational argument with Sr. Mgmt.

I have also had to argue this with consultants (and I am one!) who tell management a BSA area is overstaffed - it depends upon so many variables:

>products (do you have check cashers, lots of cash stores, restaurants, etc.)
>do you have any international customers
>who processes/files CTRs
>BSA automation (someone has to run it and follow up on the alerts!)
>does BSA also investigate kiting, check fraud, ID theft alerts

and so on.

In a $285MM bank - 1 person handling compliance, including CRA, BSA, OFAC, AML, internal controls, and coordinator with regulators, external and internal auditors and enforcement. Compliance officer told to start working operations areas too because compliance "should not take up so much time".

[Security officer handled security in name only.]

It does, however, give them a group of folks in their same size to PM and obtain more information.

what does it hurt having this thread on here? Its not that big of a deal

Although, this is not the best way to get this information, it is still usefull. Risk assessments aren't worth the paper they are on, compared to knowing what the "other guy" is doing, to justify staff. We all know that the specifics of operations can cause great differences in staffing needs, but Sr. Managers rarely want to hear that answer.

I am often asked by management how many people do other banks I see have in BSA. I always provide the numbers based on BSA related tasks:

how many work on CTRs, whereever they may be
how many on investigations
how many on fraud investigations - some have it in BSA some do not
etc.

I also specify differences in product/risk exposure: international customers, non-resident aliens, international wires, # of check cashers and other MSBs, # of other high risk customers.

I have to agree with Randy here. Though BOL is a great tool for help ... I find this question gets too many varying results with little benefit.

Take Duchess Skittles' & dottiec's bank: $210M - $600M w/4 people split up amoungst all areas.

Then take me: $1B - 1 person (me) in charge of Audit/SOX, Security/Fraud, BSA, CRA & "other duties as assigned". No assistant. And 1 person in charge of Ops AND Lending compliance (did I mention we have a Mortgage company too?)

If Duchess compared her bank to mine, just based on asset size alone, her board would probably want her to cut back. You have to find a peer group to identify with, but coming from experience, that doesn't always help either.

Your best bet if you feel you're understaffed? Get your Examiner to put it in writing.