So I recently moved to a new bank and I find the reporting structure a little different. The bank I worked for the past several years was about the same size as my new bank, around the $500 million mark. When I finished there my title was VP-Chief Risk Officer. My responsibilities were internal audit & external audit facilitator, compliance, BSA, risk management, vendor management & ISO. I picked up the last 3 items over the last few years but I have always reported to the Audit Committee with a dotted line to the bank President. I also was considered part of senior management and was included in all decision making through the budget and ALCO committees. The new bank I work for my title is VP-Compliance & Risk Manager. My responsibilities are pretty close to before minus the internal audit and ISO. Now I report to the VP of Branch Administration and am included in none of the decision making and the only committees I am involved in are the Compliance Committee and the Policy Committee. In fact now when I find an issue or make a recommendation, Senior Management meets without me to discuss and then make a decision on what to do and I may never even hear back on it. Was I too involved at my previous bank or am I not involved enough at the new bank? Should I be reporting to an operations person? Give me your thoughts.

Do you report to the Audit Committee at all? Do you perform compliance audits??

I do not really perform audits at this point but I would think if I start to perform any reviews going forward I would have to report to the audit committee. I currently do not.

The biggest difference between your current and previous jobs is that you are no longer responsible for internal audit, therefore, there is no longer a requirement that you report directly to the Audit Committee. Based on my experience, I don't see anything unusual about your current reporting structure, other than the fact that you are a VP reporting to another VP. Typically VPs report to a SVP or EVP.

Olivia - from my experience - examiners want the Compliance Officers independent also. If you are not, there may be an issue during your next compliance examination. While I don't know your job duties - being a VP in Compliance and Risk Management sounds like a higher level job - and should have that independence. The fact that you're not included when an issue you brought to someone's attention is discussed or even know the outcome is a little un-nerving to me.

Good luck!

I agree with you. I feel like regardless of the audit piece that I should be more independent. I mean I am reporting to an operations person who I may have to pick apart at some point. How's that going to work out?

Do you know anything about things worked with your predecessor?

Yes, my predecessor is still here. He is retiring in the next few months so they hired me as his replacement. He has only been here for about 2 years and when I approached him about some of these items he said that was why he had decided to retire. He wasn't used to working this way but also came from a credit union and said everything was so different that he had a hard time adjusting in general.

It has been my experience here in the South Florida market, that if you have the BSA officer title then you must be independent and report to either the Board of Directors or similar group (you can have a dotted line to the President). If you do not then your bank is at risk to being cited for you not having the proper authority to do the job, i.e file SARs, exit relationships etc..

Exactly what I have heard. Now I am not the BSA Officer but she does report to me as the risk officer. So if I reported to the Audit Committee and she reported to me it would create that independence in my mind.

I agree with that assessment.

I say give it time. The bank is still getting used to you and most of us in the industry understand that community banks differ widely on organizational structure. Just because you know you can help or assist in other areas does not mean the same to your current employer. Keep being awesome and I am sure you will have more things open up for you at your current bank.

old bank - chief risk officer
new bank - risk manager

old one is in the C-suite and generally considered senior management or executive management, new one is not C-suite and likely more middle management.

In the NY region; the old bank with IA and Compliance together would be a huge issue add to that ISO would greater increase the chance of a regulatory concern as there appears to be a lack of independence.

The new bank while on paper is slightly better in actually is worse, I would not worry about Senior Management meeting without you but not getting back to you is a huge issue and a reason for concern.

Compliance and IA (CISO and Controllers as well) should have a level of independence and not report to an directly Operations position. but a dotted line to Administration would be good. Compliance should directly report to either the board or a board committee. . I am not sure if that part is somewhat covered in your new bank.

CISO and Controllers can report to administration