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#1445178 - 09/19/10 12:19 AM Your Bank's Compliance Area
Anonymous
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I know that compliance areas are structured SOOOO differently depending on the bank, but I was wondering if most Compliance Officers were considered Senior Management or at least on the Management Team. If not, do you feel Management listens to you as a Compliance Officer? In some areas, particularly the area of BSA, I've always wondered why the regulation doesn't state that the BSA Officer has to be Senior Vice President due to the level of responsibility. It discusses the BSA Officer being ultimately responsible (other than the Board) for BSA. It seems in most banks, the hierarchy means that Senior Vice Presidents/Management has more authority than a Compliance Officer that is a Vice President or lower. I just wondered what everyone's take on that was and how their bank's Compliance Department was structured.

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#1445197 - 09/20/10 12:29 PM Re: Your Bank's Compliance Area Anonymous
RR Joker Offline
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RR Joker
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The Swamp
At our bank, the BSA officer is a VP. I'm the CO and also a VP. We are considered "senior management", since we are listed in our annual report as such, but, of course, executive management out ranks us. Having said that, we have LO's that are SVP's...do they out rank our say so? Not on your life!
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#1445198 - 09/20/10 12:36 PM Re: Your Bank's Compliance Area RR Joker
HappyGilmore Offline
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Pulling people out of the ditc...
our compliance officer is a SVP, reports to the President, presents to the Board monthly, but is not a member of executive management. Sits on our risk and audit committees.
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#1445208 - 09/20/10 01:13 PM Re: Your Bank's Compliance Area Anonymous
Last Mango Offline
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Joined: Mar 2001
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Too Far From the Beach
I'm the CO and BSA/AML Officer with a title of VP. In our shop, a VP is a middle manager. I am under no dilusion that I have the authority to cross lines and force business units to comply. Therefore, I take the approach that I must be a good salesperson to convince managers to implement policies and procedures to protect their areas of concern.
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#1445604 - 09/20/10 09:02 PM Re: Your Bank's Compliance Area Last Mango
Here4Life Offline
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I am the BSA Officer/Lending COmpliance Officer/Loan Officer & I am a AVP. I am not considered management, but the higher ups do listen especially when it is a new regulation or major change to an existing one.

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#1445612 - 09/20/10 09:18 PM Re: Your Bank's Compliance Area Here4Life
Doug Hendrickson Offline
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Doug Hendrickson
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I am the BSA officer and Compliance Officer (VP level), reporting in those capacities to a Diretor who is also chairman of the audit committee. I am part of the 'management team', although we do have EVPs and SVPs. While I can't "force" business units to comply, I, like Last Mango and probably most of us, use persuasion and the bully pulpit to gain compliance. Worst case, I can always report it to the Director, but I haven't had to yet. Most business units get the message and are just looking for me to help them do it right without a lot of time/effort/money (sometimes I can, sometimes I can't).
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1445655 - 09/21/10 01:08 AM Re: Your Bank's Compliance Area Doug Hendrickson
Bullseye Offline
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Bullseye
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Posts: 968
I am the Compliance Officer at our institution & have no "letters" in my title. I do not sit on the management team, but I do have their support.

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#1445873 - 09/21/10 03:52 PM Re: Your Bank's Compliance Area Bullseye
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
I am the Compliance Officer, CRA Officer and BSA Officer and like Bullseye, no extra letters. I don't sit in on any meetings. Head of our dept, Risk Management Officer SVP, attends all the meetings.

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#1445917 - 09/21/10 04:57 PM Re: Your Bank's Compliance Area HappyGilmore
wood2 Offline
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Joined: Apr 2010
Posts: 12
Originally Posted By: HappyGilmore
our compliance officer is a SVP, reports to the President, presents to the Board monthly, but is not a member of executive management. Sits on our risk and audit committees.


Taking the reporting issue further...I would like to know who you or your CO reports to in your organization? President, COO, CFO,etc

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#1445946 - 09/21/10 05:18 PM Re: Your Bank's Compliance Area wood2
Anonymous
Unregistered

I am the compliance and BSA Officer and an AVP. We have 2 EVPs, a ton of VPs (typically department heads) AVPs and then regular staff. I report the VP of deposit ops (doesn't make sense since i am compliance for entire bank). Does management listen? They listen...but understanding is another thing. They always want a work around or a short cut and I don't have the authority to direct anyone to do anything.

I do agree though, I think the BSA Officer should be at a higher level than AVP. I also don't have any staff- which is becoming a problem since I am drowning in paper.

eh.

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