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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In life, there is a lot less that could get better and a lot more that could get worse.
MBA Fin/MBS HR
My views only!