Skip to content
GeoDataVision
Thread Options
#1454086 - 10/12/10 03:23 PM Compliance vs Auditor
biz Offline
Diamond Poster
Joined: Nov 2005
Posts: 1,032
Midwest
I'm currently the complaince officer and the auditor. I'm looking for comments on two different scenerios. We are considering (thanks to Dodd-Frank) separating the two positions.

What concerns should I have if the audit part of the job is farmed out-I would continue to act as the scheduler of these audits and report to the AC, follow up on findings, etc.

What responsibilities would the compliance part of the job typically still be responsible for?

I've done both for so long, I'm not sure how to separate the two.

I should add department heads have been responsible for day to day compliance, new policies, etc. So when I performed audits, loan reviews as the internal auditor, there was no conflict. The role of the compliance officer, up until now, has simply been as an advisor and question answerer. How might I expect that to change.

Thanks-your comments are appreciated.

Return to Top
Audit
#1454208 - 10/12/10 06:12 PM Re: Compliance vs Auditor biz
Midnight Offline
Member
Midnight
Joined: Jun 2008
Posts: 69
Upper Mid West
Our Compliance Officer files CTRs, reviews OFAC lists, ensures CIP is followed, reviews all advertising, ensures all disclosures are up to date and are being disclosed properly, reviews hold notices, does loan file review for compliance with regulations, does HMDA reporting, reviews all denials, keeps track of loans to insiders, perfoms bankwide training on compliance as needed... Our compliance officer is also our BSA officer.

Our Internal Auditor audits all areas of the bank based on a risk assessment.

Return to Top
#1462332 - 11/02/10 01:23 PM Re: Compliance vs Auditor Midnight
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
Biz, are you the only one currently in the Audit dept? I currently am the Compliance Officer and Internal Auditor and my roles are pretty much what you stated yours are. I conduct most audits (only outsource a few of the larger more time intensive ones). I do not serve as BSA Officer though.

I have two assistants that help with monthly compliance monitoring and internal audit workpapers. Going forward, these two will separate and one will do only compliance and the other internal audit and I will remain the manager over both.

We have a loan/deposit trainer and a teller trainer that help take on the duties of training and research in those areas as well.

Return to Top
#1464819 - 11/05/10 06:08 PM Re: Compliance vs Auditor COMPLIcated
drewella Offline
Gold Star
Joined: Sep 2009
Posts: 296
Lucky you! (to have assistants)

Return to Top
#1467500 - 11/15/10 01:15 PM Re: Compliance vs Auditor drewella
biz Offline
Diamond Poster
Joined: Nov 2005
Posts: 1,032
Midwest
Yeah, no kidding. Nice to have assistants. I am the only one, and although I haven't had BSA before, I will now be taking that on as well. Thanks for your comments.

Return to Top
#1467733 - 11/15/10 06:12 PM Re: Compliance vs Auditor biz
gigi2 Offline
Junior Member
Joined: Jan 2008
Posts: 45
Geez, two assistants...what a deal! What size bank are you. I manage a $200MM bank's audit/compliance department. It includes BSA, Compliance, Internal audits, Risk, Disaster and Reoovery, IT risk, write all policies and procedures, and assist managment in way too many other things. Right now I am extremely overwhelmed with one other person helping with audits and BSA. He is overwhelmed too. Much of our work is not automated which makes even harder. Any ideas?
Gigi

Return to Top
#1474817 - 12/01/10 10:25 PM Re: Compliance vs Auditor gigi2
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
We are about $440mm in assets. We have a separate BSA Officer that is not in the Audit Dept. Our Sr. Managers over Loans and Operations are responsible for writing or updating policies as changes come out. I do manage 2 assistants that do monthly monitoring, IA workpapers, audits, etc. but duties that I still keep myself as well are employee account reviews, unclaimed property, bank wide risk assessment, Red Flags, Incident Response program, and a few other hats.

Return to Top
#1483480 - 12/21/10 05:18 PM Re: Compliance vs Auditor COMPLIcated
COnoCook Offline
New Poster
Joined: Dec 2005
Posts: 4
I am the CO (no assistants, yet) and function beside the IA dept (3 people); we are $868MM. I do all compliance audits except the BSA which we outsource and I assist. I give final approval on advertising and do the F/L analysis of the LAR. Most other actual compliance operations are handled by other staff - we have a separate BSA officer,a CRA officer, and a Training officer, etc. I answer questions, research, interpret, audit, do compliance training, attend many committee meetings, mostly as an advisor, help lead our Fin Lit activities. We stick to the rule that you can't audit your own work. And we try to keep compliance proactive as well as reactive (audits). Good Luck!

Return to Top
#1483725 - 12/21/10 09:16 PM Re: Compliance vs Auditor COnoCook
biz Offline
Diamond Poster
Joined: Nov 2005
Posts: 1,032
Midwest
Who do you report to. I don't know if no one wants me or everyone wants to keep me but, there is a debate now over who I will report to. I think for independence, I will still report to Audit Committee, but what do you all say? thanks

Return to Top
#1483788 - 12/21/10 10:56 PM Re: Compliance vs Auditor gigi2
Southern gal Offline
Platinum Poster
Joined: Mar 2008
Posts: 504
TN
Wow, gigi2 how in the world do you ever get your annual audit schedule complete?
Last edited by Southern gal; 12/21/10 10:57 PM.
Return to Top
#1485055 - 12/23/10 09:40 PM Re: Compliance vs Auditor Southern gal
gigi2 Offline
Junior Member
Joined: Jan 2008
Posts: 45
not an eazy task. Take a lot of work home to avoid the ongoing interruptions. Policy writing is very time consuming and I feel, certainly a conflict of interest. The work continues to pile up, however, the board has been kind in providing me with some outside help on 5 audits. YEA!

Return to Top
#1490669 - 01/06/11 04:06 PM Re: Compliance vs Auditor gigi2
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
I report to the Audit Committee and the Board.

Return to Top

Moderator:  Andy_Z