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#1615431 - 10/13/11 05:44 PM BSA Officer to whom do you report?
Anonymous
Unregistered

And, if you report to a CO, does this mean that he/she is responsible for BSA b/c you report to them?

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#1615477 - 10/13/11 06:18 PM Re: BSA Officer to whom do you report? Anonymous
Tater Offline
Platinum Poster
Joined: Jan 2006
Posts: 642
Missouri
I'm the BSA Officer and also the Risk Management Officer, supervising the audit/compliance/loan review department. My reporting is directly to a committee of the Board comprised exclusively of outside directors.
_________________________
Born once? Die twice.
Born twice? DIE ONCE!

Loan Review, HMDA, ALLL

Opinions are my own and do not reflect any others

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#1615488 - 10/13/11 06:23 PM Re: BSA Officer to whom do you report? Tater
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
I'm the BSA Officer and I report to the CO, who has no clue about BSA/AML. Nor does he want to. I just keep him current on SAR filings, regulatory changes and how the department is functioning. He cannot over ride me on SAR filings or anything along those matters. I have access to the CEO and/or Board if he challenges me.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1615602 - 10/13/11 08:04 PM Re: BSA Officer to whom do you report? ACBbank
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
I serve as both the BSA and Compliance Officer. I report to the SVP/CFO.

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#1615623 - 10/13/11 08:23 PM Re: BSA Officer to whom do you report? P*Q
Anonymous
Unregistered

Exactly the same as Pizza Queen.

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#1615637 - 10/13/11 08:30 PM Re: BSA Officer to whom do you report? Anonymous
Anonymous
Unregistered

Pizza Queen and Anon, does this make the SVP/CFO responsible for the program because they oversee you, the BSA Officer? i.e. BSA Policy, etc.

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#1615651 - 10/13/11 08:46 PM Re: BSA Officer to whom do you report? Anonymous
renniks Offline
Diamond Poster
renniks
Joined: Sep 2003
Posts: 2,162
New England
I am BSA and Compliance Officer. I report to the Audit Committee and the Board of Directors.

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#1615742 - 10/14/11 05:10 AM Re: BSA Officer to whom do you report? renniks
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Regardless of who the BSA Officer reports to for Administrative purposes, the BSA Officer should have unfettered access to the Audit Committee of the Board.

And not "access in name only."
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#1616254 - 10/17/11 01:00 PM Re: BSA Officer to whom do you report? Princess Romeo
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
No, I am responsible for the whole thing. Policy, training, risk assessment, monitoring, etc. I'm the first and only that examiners will speak to about BSA. It's just a formality that I "report" to the CFO. I also have direct access to the Board for BSA purposes as well.

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