OK, so I work for a small community bank and I've been working toward Compliance Officer designation for a few years (heading up new programs, training staff, going to compliance school etc).

So my boss comes to me with an offer to promote me to Compliance Officer, but it is coupled with being BSA Officer too. I HATE *&#)@_$ BSA!!!

I would think that I would be spending 80% of my time on something I don't like. At the same time, it doesn't appear like I can separate the two and only be Compliance (although in the past different people have held those designations). Thoughts???

Thanks for letting me V E N T>>>>>>>>>>>>>>>

I'd take it, but I love BSA. Sick, huh?

A lot of smaller banks have their Compliance officer wear the BSA hat. If you don't enjoy BSA and you really think that it will be 80% of your job duties, you should think about how much you really want that Compliance Officer title. Do you enjoy what you're doing now? Would it be a step up in pay? These are things that I would ask myself before going forward.

Maybe you should figure out what it is about BSA you don't like. Over all, I always found it pretty exciting. Maybe if you were in charge of it and had it running in a way you are comfortable with, you might enjoy it more.

BSA is also a hot job area - good resume fodder.

I was a compliance officer at another bank, now I am the BSA Officer. Love them both!

I'd rather be BSA than overall compliance, but as another mentioned, it is a really hot job market right now for BSA.

I'm at a smaller community bank (under 500 million) and have both titles. I would say I spend about 70% of my time on BSA, but there are days that its all compliance. For BSA, once you build a well oiled machine (if ever possible) and have processes in place it will become less of your time. Right now I'm still building.

original poster here-
Thank you all for your thoughts & responses.

As far as what it is that I don't like about BSA....I guess I just don't fundamentally agree with it. I think the government has really gone too far and I have a hard time supporting something that I think is cracked. IMOHO banks spent way too much time and effort on BSA.

At least with compliance, you are mostly dealing with consumer protection. I think if the majority of Americans understood the PATRIOT Act and the rigors of BSA, they would be horrified.

How do you do something day in/day out that you just don't agree with?? I've worked very hard for the CO designation, but don't know if I can stomach the BSA one. So that brings me back to my original question.

Then if you don't like BSA, you prob. shouldn't take the job. BSA takes up at least 50% of my time as Compliance/BSA Officer.

I am the CO at my bank ($150M). I am not the BSA Officer, but I am finding that I have to train, audit, ect.. the BSA officer. The only thing the BSA officer does is monitor currency transactions for CTR's and suspicious activity reports. I had to set up the parameters of the risk assessment, procedures for new accounts in identifying MSB's, setup and monitor the FinCen 314(a)s, implement OFAC procedures, setup BSA Conference calls, ect.... I think being both the BSA officer and the Compliance officer would be easier in my situation than trying to cover the BSA officer's butt on all the issues she isn't up on. I'm basically taking on the burden of BSA, because I know if something isn't set up correctly, it's going to be my butt anyway, since I'm the Compliance Officer of the bank.

Like others have said, you need to get past any BSA hangups. BSA is risk based too so there is some practicality to it. I am compliance officer, but serve as an advisor to a BSA Committee (We are less than $500MM). I find the arrangement works very well. No one wants it, but there is benefit to sharing the burden.

If you want to work strickly other compliance with no BSA involvement, you are going to have to move to a large organization.

I am the Compliance Officer AND BSA Officer AND Internal Audit Coordinator for a two-bank holding company. There are parts of any job that you won't like. You just need to decide if your hard work towards CO is worth passing up this time to not have to do BSA.

Fortunately, I am hiring someone to help me and expand the department. BSA monitoring will be one of the first things I pass, even though I will still be BSA Officer.

I am the Compliance Officer for a $300MM bank. I don't work directly with BSA, but there is overlap and you still need to have a working understanding. My boss (VP of Risk Management) is the BSA officer, but we bounce issues off each other and my assistant works with CTRs and CTLs. In a small bank environment, I think you will find it hard to completely divorce yourself from the BSA process even if you don't carry the BSA Officer title.

Randy said it in a nutshell...when we were still a small community bank (3 bank holding company/7 branches)I was the CO/Auditor/BSA officer and lord knows what I've probably forgotten by now.

We are now over 1B, we split Audit and Compliance around 500MM. Now we have an entire Audit Staff and BSA Staff. I still manage compliance by my lonesome and have HMDA/CRA in my department of 2. I advise the BSA committee and attend the Board's Audit Committee meetings. One of the auditors now does the compliance audits so I can focus more on the day-to-day issues and problem solving.

Sometimes you have to "go around the world" to get to a point of where you really wanted to be.

Unregistered--Don't confuse compliance with BSA regs with agreement with BSA regs. I, too, take exception with many of the tasks under BSA, but that does not impact my enthusiasm in managing the tasks. I don't write the laws, I just work hard to keep the bank in compliance with the them all. The job is challenging, but it is exciting and the risk certainly keeps you on your toes! It is a good career path.

I tell my bankers on a regular basis that I don't agree with most of the Regs, but rules are rules and if you don't like em'...banking is no the place to be...but boy do I have job security because I understand them and the risks associated with them. I think to be successful in BSA/Compliance/Risk management, you really have to disconnect what makes sense and just look a the risk.

Its the world we live in

Unregistered--
I'm not a banker, so as an outsider I was very interested to read your comment "I think if the majority of Americans understood the PATRIOT Act and the rigors of BSA, they would be horrified."
Several things occur to me: as the system is currently configured, when conscientious people like you avoid BSA jobs it simply means that those who do BSA can command a higher salary. It will get done, right? Then again, Nuremberg stands as the our best example: don't do the wrong thing just because your government tells you to-- whether or not there is a backlash later you cannot expect to remain blameless.
Since (I assume!) BSA does not rise to the same serious level of absolute evil as Nazi war crimes, however, I'm wondering if a middle way might not be workable: if you accepted this position, would you be able to blog in some considerable detail about your experiences without violating privacy rights and BSA/Bank rules? Perhaps you could accept this distasteful side of the job for the greater good of educating the public as to the nitty-gritty of the BSA. (I don't mean to suggest that the end justifies the means--if implementing BSA is truly repugnant to you (I have no CLUE what BSA is, LOL!) then you must not do it!) This could theoretically be more a case of "changing the system from the inside" than "selling out to the man." I apologize if this is completely off the wall due to my own ignorance, but I'm hoping it's food for thought.
--Karen

consecutive post--
I'm not sure if I was clear. I realize that you *personally* cannot change the regulations from the inside. My point is that the public cannot insist that the regs be changed if the public is not sufficiently aware of what is going on.
--Karen

I'd take the job.

Then I'd go out and learn not just what the regs say, but also why they were put in place. Everyone of them were enacted for a reason - even BSA. Its easy to lose sight of the fact that we don't operate inside a bubble. All of our transactions have an effect somewhere down the line.

I mean, I don't agree with some traffic laws, but I observe them and understand why they are in place. Same kind of thing here, its all about controlling how the money moves and making sure no one gets hurt in the process.

Don't take the job! Life's too short to spend ten to 12 hours a day doing something you don't enjoy!