A thread elsewhere about a tiny BSA department in a $2bn+ institution got me wondering. What is your asset size and how many dedicated BSA professionals do you have? Not compliance generalists, I mean staff that do nothing but BSA full-time.

$1.5 billion assets / 3 full time staff, including BSA Officer

about $250 Million in assets....1 BSA Officer 1 part timer

almost $600 million 1 BSA Officer

1.2 Billion with one part time BSA Officer

2.7 with 7 plus officer.

4.5B with 3 full time staff and a manager/BSA Officer.

7.5B with 9 full time staff (which includes me). I still think we are understaffed.

Asset size is not the sole driving factor to the number of FTEs a department may need. You must also consider the volume of higher-risk customers and the types of higher-risk products and services you offer.

I had a client that was a small bank that decided to specialize in non-bank financial institutions because of the opportunity for non-interest income. Since they were only $150 million in assets, they felt that they were good with a single BSA Officer to handle everything. As a result, examiners found that that one person was way behind on EDD which resulted in a consent order. Even at $150 in assets, they now have a department of four to manage the workload of EDD, CTRs, monitoring alerts, etc. for all their high-risk customers.