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#2007098 - 04/09/15 04:03 PM BSA - job description & evaluation for non BSA Dpt
Calmeida12 Offline
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We are in the middle of a FDIC exam and the examiner is asking if job descriptions for branch and loan staff make reference of meeting and following Bank BSA requirements?
Also, if annual written performances for those same type of employees take into consideration if they've followed proper BSA procedures? Thank you.

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#2007118 - 04/09/15 04:42 PM Re: BSA - job description & evaluation for non BSA Dpt Calmeida12
#Just Jay Offline
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Cheeseheadland
Only you can answer that question for them by looking at your job descriptions and performance evals to determine if they do or not. They are asking you if yours specifically do, not if they should.

As a side note, I think most institutions include these BSA specific items in job descriptions and performance evals these days, or at least ours do.
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#2007125 - 04/09/15 05:02 PM Re: BSA - job description & evaluation for non BSA Dpt Calmeida12
Calmeida12 Offline
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We do not. Do you have sample language of what you have in yours that you could share. Thank you!

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#2007547 - 04/10/15 08:38 PM Re: BSA - job description & evaluation for non BSA Dpt Calmeida12
Elwood P. Dowd Offline
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I suggest you broaden your language to indicate: The employee is responsible for knowing and meeting the compliance requirements imposed on the bank by state and federal law as they affect his or her responsibilities.

The Bank Secrecy Act is not the only law your bank must comply with...
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#2038259 - 09/14/15 02:11 PM Re: BSA - job description & evaluation for non BSA Dpt Calmeida12
happyauditor Offline
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happyauditor
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NY
Sorry to revive an old thread...

the BSA FFIEC manual states the following:

Incorporate BSA compliance into the job descriptions and performance evaluations of bank personnel, as appropriate.

Have any banks been criticized for only having a generic statement regarding compliance with all state and federal laws as required and NOT having BSA specifically mentioned...especially for positions with direct BSA related responsbilities (such as tellers or those responsible for completing CTRs, MILs, fornt line personnel that could recognize and escalate suspicious activity, etc.)?

Thanks.
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#2039008 - 09/17/15 12:37 PM Re: BSA - job description & evaluation for non BSA Dpt Calmeida12
E.E.G.B Offline
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the sandy shore
We bring it up in the audit if we find that employee knowledge / noncompliance is contributing to substantive deficiencies. I've seen some regulators mention it too.
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