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#1583906 - 07/27/11 06:16 PM Compliance Program
Banker Offline
100 Club
Joined: Oct 2007
Posts: 128
Southeastern US
I am technically in audit but I am helping our compliance area do some updating to our compliance program. I hate to say that our monitoring portion is not on point. Since we are a small community bank, we have a compliance officer and that is it for the compliance staff. So, some monitoring is done in different areas (deposit operations does some deposit compliance monitoring, etc). Should the CCO also be reviewing their monitoring to ensure that it is complete? I know that it sounds ridiculous. I guess I am asking do you all have someone in compliance that monitors the monitoring? Since the CCO is ultimately responsible, it kind of makes sense to me. Am I going overboard? Any thoughts?

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Audit
#1584657 - 07/28/11 05:44 PM Re: Compliance Program Banker
AFaquir Offline
Platinum Poster
AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
MJoyner-

There are several viewpoints on this issue. For me and in my opinion you might be going a bit overboard. Ultimately the CCO is responsible for the total compliance program, which includes reports, but that doesn't mean that the CCO is or should be mandated or required to review reports that fit into a low risk profile. Case in point, Reg D. I check Reg D reports periodically, but I know they are reviewed daily by operations. I know our procedures and policies and my spot check is to only ensure that we can "trust" the report. In general our Reg D procedures and training are very strong and our employees know what to do when things happen. So the bank's compliance is never in jeopardy if I don't check or monitor a report or check and review the monitoring of someones report...

In all I think spot checks to me fall under the umbrella of audit not of compliance. My rule of thumb is 99% of daily compliance is done outside the compliance office. My job is to build, design and enforce a culture of compliance and be ahead of changes.

Just my opinion.

Cheers!

Last edited by AFaquir; 07/28/11 05:46 PM.
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#1586734 - 08/03/11 03:33 AM ALLL repairment testing Banker
Help!!! Offline
Member
Joined: Aug 2011
Posts: 51
Arkansas
Is there a spread sheet or word document created any where that is good to use on impairment testing?

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#1587428 - 08/04/11 01:39 PM Re: ALLL repairment testing Help!!!
complylady Offline
Platinum Poster
complylady
Joined: Jul 2002
Posts: 614
Michigan
We are a small bank and monitoring is done at the department level. I checked everything when I first came to be sure everything was working as intended (did find some issues). We use a third party for audits and they recently suggested using a spread sheet for the areas to sign on a monthly basis as evidence the monitoring was completed in order to give us credit for our internal monitoring. We were not excited about this suggestion and not implemented this procedure. We would just be passing a spreadshhet around every month and saying initial, just doesn't seem to serve much of a purpose as our procedures outline our processes. Has anyone else had this suggestion, and if so have you implemented it?

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#1589437 - 08/09/11 01:57 PM Re: ALLL repairment testing complylady
Banker Offline
100 Club
Joined: Oct 2007
Posts: 128
Southeastern US
Complylady--are the examiners content with your monitoring at the department level? That approach makes most sense in many areas for us as well. Just curious how they view that. I would also be interested in what kind of spreadsheet/documentation others are keeping if they are handling it this way.

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#1589505 - 08/09/11 02:51 PM Re: ALLL repairment testing Banker
jim mathews Offline
Member
Joined: Feb 2008
Posts: 52
Brighton Co
In our small bank I am the internal auditor as well as the compliance officer. I have two others working in the dept. Since I act as the compliance officer I do not do audits on compliance related areas, the other two do these. We are an FDIC bank and for my past 16 years they have had no problems with this procedure. We have the departments monitor their programs but do ask me questions and I also provide training on various compliance issues.

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