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.

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.

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.

Lucky you! (to have assistants)

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.

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

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.

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

Wow, gigi2 how in the world do you ever get your annual audit schedule complete?

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!

I report to the Audit Committee and the Board.