We had that set up at my last bank too. We had a designated Trust Compliance Officer though. She reviewed trust docs, new account docs, profiles, did training, etc (she was not our Trust Ops Mgr though-that was a different position). She also ran the 314a and reviewed OFAC hits. Our examiners wanted me as BSA Officer to review and sign off on her 314a's, otherwise they were good with our program.