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#289105 - 12/14/04 09:55 PM BSA Officer
kfh Offline
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Joined: May 2004
Posts: 149
GA
I'm curious as to the "rank" of institution's BSA officers. Is your BSA Officer an SVP, EVP, etc. Is the person who acually handles the day to day compliance? If not, who is the person that does, another lower level officer, or regular employee?

We are a $250 million community bank. Our SVP/CFO is the BSA Officer, but as compliance officer I handle all day to day issues, training of staff, etc.

I'd like to see the setup in other similar sized institutions.

Thanks.

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#289106 - 12/14/04 10:23 PM Re: BSA Officer
GuitarDude Offline
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So Cal
I can't comment based on FI size, but I would offer that your regulator may be able to provide guidance. My bank's BSA oficer is an AVP and this was satisfactory to our regulator (OCC) when the appointment was made.

A strong consideration is the person's focus and job responsibilities. The BSA Officer is responsible for all things BSA that occur, good or bad. IMO that means that BSA must be the primary focus of the appointee and not just a title for oversight purposes. CFOs may not be able to devote the time to BSA that your regulator would like to see, however some authority is necessary.
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#289107 - 12/14/04 11:13 PM Re: BSA Officer
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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We too have a more junior level person (not an SVP) as the BSA/AML officer. It is a full time job, they have a staff, they have management that fully supports their responsibilities and that senior support gives them the authority to make sure compliance occurs.
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#289108 - 12/15/04 01:09 PM Re: BSA Officer
Elwood P. Dowd Offline
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Next to Harvey
Rank isn't necessarily relevant. Power is. From the FDIC's FIL 58-96 :

The senior bank official in charge of BSA compliance should be in a position, and have the authority, to make and enforce BSA policies. A "BSA Officer" who reports to a senior official is not sufficient to meet the requirements. The senior official should be designated as the BSA Officer. Assigning overall compliance responsibility to a lower level employee who does not have sufficient authority to direct the development and execution of a BSA program could jeopardize the efficacy of that program. The title of the individual responsible for overall BSA compliance is not important; however, the individual's level of authority and responsibility within the institution is.

In banking, titles oftentimes do not tell the story. I once worked for an institution where the EVP's primary duties seemed to be monitoring employee use of the copy machine and approving magazine subscriptions. However, the ability to "make and enforce policies," ahh, that's power.
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#289109 - 12/15/04 02:23 PM Re: BSA Officer
trout22 Offline
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Joined: Nov 2004
Posts: 313
Our current officer is the employee who has the most year's experience (over 50) at our bank. The only downside is...we're not doing as much electronically as we could.

I would prefer to take on that responsibility myself (as the compliance officer) if/when the position becomes available. I'm fairly young, very much into technology and online time-savers. As I understand it, many banks combine these positions... any comments??

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#289110 - 12/15/04 02:24 PM Re: BSA Officer
P*Q Offline

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We are $250M bank and I'm the BSA Officer, VP level. I also handle all of the day-to-day BSA activities such as monitoring, CTR filing, etc.

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#289111 - 12/15/04 03:05 PM Re: BSA Officer
Wore Out Offline
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Wore Out
Joined: Dec 2003
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Kentucky
Quote:

Rank isn't necessarily relevant. Power is.




I agree with Ken, it's not a matter of rank or title, it's all in the application and enforcement. I am both the compliance officer and BSA officer (among a few other designations!) and we are a $110 million in assets. The key to this position for the regulators are:
1.) Board appointed with sufficient enforcement ability to cross all lines of business
2.) Knowledge of the regulations to design, apply, and enforce the bank's overall BSA/AML policy
3.) Sufficent monitoring procedures that are documented and tested
4.) Frequent updates to Senior Management & the board on the overall condition of the program.
5.) The ability to discipline any employees (with their managements involvement) who violates the policy and procedures approved by the board.
6.) Whatever else your regulators would like to see or recommend!

Hope this helps
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#289112 - 12/15/04 03:08 PM Re: BSA Officer
Anonymous
Unregistered

We are a $759 million bank with 18 branches. The BSA Officer is a SVP and also the Compliance and CRA Officer.

My exact title is BSA/Compliance Assistant. I handle the day-to-day tasks of BSA monitoring for CTRs, SARs, etc. I review all CTRs for accuracy and then the BSA Officer signs them. I complete all research and fill out SARs and the BSA Officer reviews them and approves them. We are both 314(a) contacts, although I actually do the searches.

I basically do all the legwork and the BSA Officer signs and approves everything.

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#289113 - 12/15/04 03:15 PM Re: BSA Officer
OnTheEdge Offline
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SmallTown, USA
Be careful what you wish for.....
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#289114 - 12/16/04 06:29 PM Re: BSA Officer
I Wear Many Hats Offline
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the beautiful state of ME
I am a senior level Compliance and BSA Officer (along with CRA and Reg O). Line employees do most of the legwork but I am responsible for the overall program and am on the hook for the audits and exams.
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#289115 - 12/16/04 06:53 PM Re: BSA Officer
Pop Pop Offline
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Joined: Dec 2003
Posts: 34
Florida
We are a $250 million, FDIC regulated bank with 6 branches. I am the BSA Officer, CRA Officer, Compliance Officer, and AVP. I was appointed AVP recently after a good BSA review by our regulators.

My official title is Compliance Officer. I handle the day-to-day tasks of BSA monitoring for CTRs, SARs, etc. I review all CTRs for accuracy before mailing them. I make the final decision on the filing of SAR's.

What I have read indicates the regulators are looking for someone with raw power within the bank (like the CEO's secretary, as an example) more than someone with a title. They want the BSA Officer to be strong enough to stand up to an EVP or a CEO and tell them BSA rules and policies will be followed over the higher ranking officer's objections.

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#289116 - 12/16/04 10:15 PM Re: BSA Officer
Elwood P. Dowd Offline
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Next to Harvey
Quote:

like the CEO's secretary, as an example




Sorry, but I don't think the BSA Officer has to have that much power.
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#1496146 - 01/17/11 06:50 PM Re: BSA Officer Elwood P. Dowd
leo_bsayer Offline
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Hey guys. I just noticed the last post here is 2004. We've had several changes to BSA since then. I just wondered if you still felt the same about BSA as you did then. Also, do you feel it is acceptable to be the BSA Officer as well as the Compliance Officer? Do you treat those jobs exactly the same?

When I say exactly the same, btw, I mean, for those of you who are both BSA and Compliance Officer, do you go about your other areas of compliance just as you would BSA?
Last edited by leobsayer; 01/17/11 09:03 PM.
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#1496622 - 01/18/11 08:38 PM Re: BSA Officer leo_bsayer
SnowRed Offline
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Posts: 42
East Coast
I am currently the BSA officer and compliance officer for a 1.2 billion institution. There is one assistant in place that takes care of CTR filing and some SAR investigations. I think it is too much for one individual, but I am so new I am afraid to bring it up.
The FI I left had a compliance officer and a BSA officer plus two assistants. They were only $800million and still had their share of problems. I'm not sure what you mean by "do you go about your other areas of compliance just as you would BSA".

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#1496725 - 01/18/11 10:39 PM Re: BSA Officer SnowRed
leo_bsayer Offline
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Thanks for that information SnowRed. I guess what I meant was, if you are both BSA and Compliance Officer, do you treat both jobs equally, or as BSA Officer, do you have more responsibility than you do as Compliance Officer. Do you have access to senior management and the Board?

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#1496783 - 01/19/11 01:37 PM Re: BSA Officer leo_bsayer
Dani York, CRCM Offline
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TN
I am both the BSA Officer and the Compliance Officer, no assistants. Both carry equal weight with regard to authority at my institution (152 million). I have direct access to the Board and senior management. I do find that it is difficult to devote equal time to both positions on a daily or even weekly basis. I'm either working on totally BSA or totally on regulatory compliance.
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#1497416 - 01/20/11 01:57 PM Re: BSA Officer Dani York, CRCM
P*Q Offline

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I am both in a $450Million institution and have 2 assistants, one full and one part time.

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#1497754 - 01/20/11 05:35 PM Re: BSA Officer P*Q
Retired DQ Offline
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Turnpike Exit 10
3.6 B/40 branches
Compliance officer w/ 1 asst; BSA officer with 2 assts.
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#1497963 - 01/20/11 08:23 PM Re: BSA Officer leo_bsayer
SnowRed Offline
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Joined: Oct 2010
Posts: 42
East Coast
Like another poster, I am either doing BSA or compliance or whatever other research that noone wants to do. I tend to work in bursts of BSA rather than touch it every day. As far as time is concerned I should be spending more time in each area. I think BSA officer could be a full time job (in an institution this size) to do right, so being an effective compliance officer (which used to be a more than full time position before)in addition is very difficult. I worry I can't keep all balls in the air.

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