I've been a BSA Officer for one year. My previous position with the bank was Branch Manager & Teller Trainer & CSR (opened new accounts).

I seem to remember from a trainer that perhaps a BSA Officer shouldn't be working the teller line.
As in all banks, there's a certain level of turn-over on the teller line. Then vacations, maternity leave, training out of the bank, illnesses are other reasons why the branches are short-handed.

In those cases, do you think it's acceptable for the BSA Officer to assist at a branch on an occasional basis to get through the tough times?

I still open accounts for customers as back-up for the CSR when she is out of the bank or at lunch. But I have not been on the teller line since becoming the BSA Officer.

We do have an assistant BSA Officer who submits CTRs. If I conducted a transaction that required a CTR, I wouldn't be the one ultimately submitting the CTR. So we do have segregation of duties.

Any comments are appreciated.

Last week I talked to a banker trying to deal with an examiner who said the BSA officer should not be a lender. The examiner cited it as an internal control issue. I thought it was poppycock.

Very few community financial institutions have a full time BSA Officer. Thus, as a rule, the BSA officer has simultaneous functional responsibiities within the institution. Obviously, the BSA Officer cannot be a part of the BSA audit. Aside from that I know of no "rules" that say he or she cannot occupy any other functional role.

Ken - Thank you for your comment. I think my F.I. has enough checks & balances in place between myself and the assistant BSA Officer for me to occasionally assist with the teller line.

I certainly don't want to get my hand whacked by an examiner. I try always to stay on the right side of the law.

You're welcome, but I'm hoping you will generate some more comments...

For several years I worked as both as the Head Teller and the main BSA function. I was not the named BSA Officer at the time, but did all of the duties. There was never any issue during exams or audits as we had good internal controls in place.

I wish I had an assistant BSA Officer. I have asked for help several times but keep getting denied. Here I was told that I am not supposed to touch the cash or conduct any of the cash audits but I am the BSA Officer, Internal Auditor, Compliance Officer, and the Mortgage Quality Control Manager. We have about 50 employees across 4 branches and I have asked for help because I feel it is nearly impossible to complete the duties for each position thoroughly.

Sorry I got a little off track from the original topic.... I think that if you have limited staff then you have to do the best you can as long as you have appropriate checks and balances and segregation of duties.

I'm the BSA officer here and teller a minimum of one Saturday a month (everyone below a VP title has to, except the IA). I don't participate in the audits and it wasn't deemed an issue during our last exam.

I'd like to argue that I shouldn't, but mostly because I'd like to get out of working Saturdays

My bank would never let me be a teller.

I would love it, but I would probably chase away a lot of the "good" customers I've been filing SARs on because no one will ask them any questions.