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#289105 - 12/14/04 09:55 PM
BSA Officer
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100 Club
Joined: May 2004
Posts: 149
GA
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I'm curious as to the "rank" of institution's BSA officers. Is your BSA Officer an SVP, EVP, etc. Is the person who acually handles the day to day compliance? If not, who is the person that does, another lower level officer, or regular employee?
We are a $250 million community bank. Our SVP/CFO is the BSA Officer, but as compliance officer I handle all day to day issues, training of staff, etc.
I'd like to see the setup in other similar sized institutions.
Thanks.
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#289106 - 12/14/04 10:23 PM
Re: BSA Officer
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Power Poster
Joined: Nov 2004
Posts: 5,925
So Cal
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I can't comment based on FI size, but I would offer that your regulator may be able to provide guidance. My bank's BSA oficer is an AVP and this was satisfactory to our regulator (OCC) when the appointment was made.
A strong consideration is the person's focus and job responsibilities. The BSA Officer is responsible for all things BSA that occur, good or bad. IMO that means that BSA must be the primary focus of the appointee and not just a title for oversight purposes. CFOs may not be able to devote the time to BSA that your regulator would like to see, however some authority is necessary.
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I've just writed a wrong.
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#289108 - 12/15/04 01:09 PM
Re: BSA Officer
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Rank isn't necessarily relevant. Power is. From the FDIC's FIL 58-96 :
The senior bank official in charge of BSA compliance should be in a position, and have the authority, to make and enforce BSA policies. A "BSA Officer" who reports to a senior official is not sufficient to meet the requirements. The senior official should be designated as the BSA Officer. Assigning overall compliance responsibility to a lower level employee who does not have sufficient authority to direct the development and execution of a BSA program could jeopardize the efficacy of that program. The title of the individual responsible for overall BSA compliance is not important; however, the individual's level of authority and responsibility within the institution is.
In banking, titles oftentimes do not tell the story. I once worked for an institution where the EVP's primary duties seemed to be monitoring employee use of the copy machine and approving magazine subscriptions. However, the ability to "make and enforce policies," ahh, that's power.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#289109 - 12/15/04 02:23 PM
Re: BSA Officer
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Gold Star
Joined: Nov 2004
Posts: 313
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Our current officer is the employee who has the most year's experience (over 50) at our bank. The only downside is...we're not doing as much electronically as we could.
I would prefer to take on that responsibility myself (as the compliance officer) if/when the position becomes available. I'm fairly young, very much into technology and online time-savers. As I understand it, many banks combine these positions... any comments??
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#289112 - 12/15/04 03:08 PM
Re: BSA Officer
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Anonymous
Unregistered
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We are a $759 million bank with 18 branches. The BSA Officer is a SVP and also the Compliance and CRA Officer.
My exact title is BSA/Compliance Assistant. I handle the day-to-day tasks of BSA monitoring for CTRs, SARs, etc. I review all CTRs for accuracy and then the BSA Officer signs them. I complete all research and fill out SARs and the BSA Officer reviews them and approves them. We are both 314(a) contacts, although I actually do the searches.
I basically do all the legwork and the BSA Officer signs and approves everything.
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#289113 - 12/15/04 03:15 PM
Re: BSA Officer
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Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
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Be careful what you wish for.....
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The opinions expressed are mine and do not necessarily reflect those of my employer.
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#289114 - 12/16/04 06:29 PM
Re: BSA Officer
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Platinum Poster
Joined: Mar 2001
Posts: 591
the beautiful state of ME
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I am a senior level Compliance and BSA Officer (along with CRA and Reg O). Line employees do most of the legwork but I am responsible for the overall program and am on the hook for the audits and exams.
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The paradox of planning is nothing happens....
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#289115 - 12/16/04 06:53 PM
Re: BSA Officer
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Junior Member
Joined: Dec 2003
Posts: 34
Florida
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We are a $250 million, FDIC regulated bank with 6 branches. I am the BSA Officer, CRA Officer, Compliance Officer, and AVP. I was appointed AVP recently after a good BSA review by our regulators.
My official title is Compliance Officer. I handle the day-to-day tasks of BSA monitoring for CTRs, SARs, etc. I review all CTRs for accuracy before mailing them. I make the final decision on the filing of SAR's.
What I have read indicates the regulators are looking for someone with raw power within the bank (like the CEO's secretary, as an example) more than someone with a title. They want the BSA Officer to be strong enough to stand up to an EVP or a CEO and tell them BSA rules and policies will be followed over the higher ranking officer's objections.
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#1496146 - 01/17/11 06:50 PM
Re: BSA Officer
Elwood P. Dowd
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Platinum Poster
Joined: Aug 2006
Posts: 645
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Hey guys. I just noticed the last post here is 2004. We've had several changes to BSA since then. I just wondered if you still felt the same about BSA as you did then. Also, do you feel it is acceptable to be the BSA Officer as well as the Compliance Officer? Do you treat those jobs exactly the same?
When I say exactly the same, btw, I mean, for those of you who are both BSA and Compliance Officer, do you go about your other areas of compliance just as you would BSA?
Last edited by leobsayer; 01/17/11 09:03 PM.
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#1496622 - 01/18/11 08:38 PM
Re: BSA Officer
leo_bsayer
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Junior Member
Joined: Oct 2010
Posts: 42
East Coast
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I am currently the BSA officer and compliance officer for a 1.2 billion institution. There is one assistant in place that takes care of CTR filing and some SAR investigations. I think it is too much for one individual, but I am so new I am afraid to bring it up. The FI I left had a compliance officer and a BSA officer plus two assistants. They were only $800million and still had their share of problems. I'm not sure what you mean by "do you go about your other areas of compliance just as you would BSA".
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#1496725 - 01/18/11 10:39 PM
Re: BSA Officer
SnowRed
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Platinum Poster
Joined: Aug 2006
Posts: 645
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Thanks for that information SnowRed. I guess what I meant was, if you are both BSA and Compliance Officer, do you treat both jobs equally, or as BSA Officer, do you have more responsibility than you do as Compliance Officer. Do you have access to senior management and the Board?
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#1496783 - 01/19/11 01:37 PM
Re: BSA Officer
leo_bsayer
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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I am both the BSA Officer and the Compliance Officer, no assistants. Both carry equal weight with regard to authority at my institution (152 million). I have direct access to the Board and senior management. I do find that it is difficult to devote equal time to both positions on a daily or even weekly basis. I'm either working on totally BSA or totally on regulatory compliance.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
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#1497754 - 01/20/11 05:35 PM
Re: BSA Officer
P*Q
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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3.6 B/40 branches Compliance officer w/ 1 asst; BSA officer with 2 assts.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1497963 - 01/20/11 08:23 PM
Re: BSA Officer
leo_bsayer
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Junior Member
Joined: Oct 2010
Posts: 42
East Coast
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Like another poster, I am either doing BSA or compliance or whatever other research that noone wants to do. I tend to work in bursts of BSA rather than touch it every day. As far as time is concerned I should be spending more time in each area. I think BSA officer could be a full time job (in an institution this size) to do right, so being an effective compliance officer (which used to be a more than full time position before)in addition is very difficult. I worry I can't keep all balls in the air.
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