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#9494 - 01/25/02 03:56 PM Staff size?
Leslie Wallace Offline
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Joined: Dec 2001
Posts: 24
Indiana, PA, USA
Does anyone one have any comparisons on "compliance department" size and staffing based on bank size, # of branches, etc? I am the Compliance, CRA, BSA/OFAC, and Privacy officer at my bank which has 40 branches in 7 counties and assets of 2.3 billion. I want to convince senior management that I need at least a part time person to assist me!!!!!!!!

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#9495 - 01/25/02 04:39 PM Re: Staff size?
Rubaiyat Offline
Diamond Poster
Joined: Jun 2001
Posts: 1,373
Lido Deck
When do you sleep, Leslie?? We are a $1.4 billion bank with 10 branch locations. We have two compliance officers, a CRA officer, a security officer and a part time compliance assistant. And we are all barely keeping our heads above water! In our last compliance exam the OCC suggested (but didn't go so far as to make it a recommendation) that we could use additional staff. We are a fairly complex bank for our size and I can't imagine one person doing it all!
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#9496 - 01/25/02 04:53 PM Re: Staff size?
cwiza Offline
Junior Member
cwiza
Joined: Mar 2001
Posts: 37
Lakeland, FL USA
Leslie, I cannot see how you can function with all those responsibilities! I am the compliance and CRA office for our community bank that, after our acquisition is complete, will have 18 branches and approximately $850 million in assets. I am primarily responsible for lending compliance and CRA. I just received permission and have hired another full-time assistant and have one other assistant who has part-time compliance duties. The bank also has a separate compliance officer for the deposit function and another officer who has security responsibilities. Just another note since I've spent a good deal of time developing the compliance and CRA program from the ground up, we currently outsource our compliance audits. I have been nearly drowning for two years in this position, and I would suffice to say you REALLY need extra help and not just a part-timer. One or two additional full-time staff for your asset size would be my opinion just to try to keep you ahead of the ball game. Good luck!

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#9497 - 01/25/02 06:50 PM Re: Staff size?
prosperity Offline
Member
prosperity
Joined: Oct 2001
Posts: 82
Houston, TX
Leslie,

I share your position. I'm with a $1 billion company with 30 locations in at least 7 counties and am compliance and CRA formally. I am also share BSA and OFAC and any other regulation or rule that someone thinks I should be involved with. There is an assistant, but I'm in one city and she is an hour away and is soo green. We can only do what we can do.


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#9498 - 01/25/02 07:51 PM Re: Staff size?
Anonymous
Unregistered

We are at $750+, 20 branches, 5 counties; one compliance officer, one compliance specialist, one BSA/OFAC officer, one security/privacy officer and one CRA officer. How do you do it?

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#9499 - 01/25/02 08:08 PM Re: Staff size?
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,384
On the Net
OK, how about $360MM but transaction counts comparable to a $2B bank, 72 branches that go from the top of Texas to the bottom and left edge to right. We also have nearly 500 ATMs.

I do the compliance less BSA/OFAC and our Internal Audit dept. handles the BSA and Reg. CC audits. We have a training department that handles most of those issues, but with my input on what to cover. Actually I do a lot of the compliance training of new hires in my region and they use my materials elsewhere.

I also inherited Security but have 2 Security Officers and 2 other staffers for that.

Otherwise, its just lil'ol me... and BOL. Without networking, it could not be done at an acceptable level.

------------------
Andy Zavoina
Opinions stated are not necessarily that of my employer.

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#9500 - 01/25/02 09:41 PM Re: Staff size?
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Leslie! My goodness! Your company must be extremely tight. I work for a smaller organization (less than $250 million) and it's just me (well I had a little help the last year or so I was there). I left a bank that was $750 million with 30 locations and there I had to do compliance ( without even as much as internet access or email) AND run the audit team. During this time I also helped open new banks, sometimes out of town and came into the office and worked nights.
Boy did I wise-up!

You need help!


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#9501 - 01/26/02 12:49 AM Re: Staff size?
Anonymous
Unregistered

Lelise,

We are large commercial bank ($10B+ assets) with 60 branch locations. We have a Corporate Compliance officer, 1 Loan Compliance officer, I P/T CRA Compliance person, and a staff of 4 other compliance people that handle all of the transaction and deposit compliance duties. One of those people handles centralized REG Complaints, another BSA activities, and the other BSA data input and other more clerical activities. We are also looking to add 1 more person to that area. I think it might be to hard for you to try to match your bank size to compliance staff with out more clearly defining and comparing what it is you actually do. Each bank is different. You are welcome to contact us and we will share statistics on activities etc with you.
Aloha
First Hawaiian Bank - 808-844-3873
Jeff.Alves@FHWN.COM


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#9502 - 01/26/02 03:10 AM Re: Staff size?
Richard Insley Online
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Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
This is an interesting "discovery" thread that could be expanded into a new BOL feature--perhaps an anonymous database that could be sorted and queried to reveal the staffing levels at similar institutions. The vast differences mentioned above are attributable to a number of factors, including:
- your product line (ex-it doesn't take much time to manage HELOC compliance in TX)
- your delivery channels (the higher the number of direct and indirect delivery channels, the larger the staff to keep the lid on)
- your location (rural banks usually enjoy relaxed demands from their regulators; state/local law can add duties [predatory lending, for example]; and if you're in FL or a few other states, BSA/AML becomes a religion--not a reg)
- your regulator (OCC expects more structure [translated: "staffing"] than other regulators)
- your definition of the "C" word (it's a type of management for some, an extension of operations or legal for some, a type of audit for others, and a dumping ground or terminal disease at some banks)
- your corporate culture and risk tolerance (risk-averse banks will not hesitate to grow staff to protect the bank's reputation)
- your history (if you're under a MOU, your staffing will reflect the concessions to your regulator)
- your profitability (struggling banks cut corners and staff)
- your size (as measured in footings, # of branches, # of employees, # of CTRs, types of loans, HMDA/non-HMDA, # & type of non-traditional businesses, etc., etc., etc.)

Given any bank's profile, staffing levels should be easier to predict or justify.

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#9503 - 12/12/02 03:03 PM Re: Staff size?
Anonymous
Unregistered

I will not disclose my identity or the Bank that I work for, however, it took a scandal that hit the front pages of the Wall Street journal, NY Times, etc. that we wised-up and went from 4 Compliance Officers to more than 80. Hopefully your Bank will also wise-up before they too get hit with sanctions and unwanted negative publicity.

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#9504 - 12/12/02 03:12 PM Re: Staff size?
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
80 Compliance Officers!?!?! How large is the bank? I work for a 1 billion $ Bank and their is only me and the Compliance Officer!
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#9505 - 12/12/02 07:01 PM Re: Staff size?
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Leslie we're a similar sized bank. ($2billion) with myself as the full time CRA officer & Community Relations Coordinator (bank cheerleader). I have a full time technical assistant and am looking to bring on another full time staff for secretarial duties (what my technical assistant should do but hasn't time). I ONLY handle CRA and Community Relations. It's a full time job with no room for more. We have 27 branches located over a state larger than Texas, California and Montana combined (that means TRAVEL) and 18 ATM's scattered throughout the arctic. (We work with the treasury department because our atm's are the most rural in America).

We have two attorneys heading up compliance, a full time compliance officer, five audit staff and three assistant position staff to support those folks.

We are one of the most profitable banks in the nation and also hold an Outstanding in CRA as well as being ranked one of the safest banks in the nation.

Without this staff level I can't imagine our CAMEL rating would stay the same, as well as our CRA rating. It takes time and people to keep a bank running profitably...and safely. Where are your ratings sitting? That might be a place to start with management. We're proof you can be profitable, and invest in compliance.

I hope you see some help soon!!!!
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#9506 - 12/12/02 08:03 PM Re: Staff size?
Pale Rider Offline
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Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
Each bank is so unique, I am the sole compliance officer for a $3 billion and (90 branch) bank, although I have 2 assistants. A separate Security officer handles BSA/OFAC etc. We are in 10 MSAs and handle much of the responsibilites through committees. An 8 person internal audit staff is my eyes and ears out in the field. It took a while to train them but this works fine now. We do a bank wide compliance audit every year. I am also responsible for CRA, Appraisals and Loan Review. Those departments have their own staff as well.
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#9507 - 12/13/02 04:29 PM Re: Staff size?
c.a.r Offline
Gold Star
c.a.r
Joined: Oct 2002
Posts: 377
Texas, USA
We are small 140m 3 branches, I am the new compliance officer, internal audit. I do BSA, SAR, OFAC already. I also do accounts payable and answer teller questions. Until last month I was full time trainer and relief for teller and new accounts. I was also informed I will be learning the securities side...
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#9508 - 12/13/02 04:59 PM Re: Staff size?
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
Being part of the new compliance dept. of 2, it is already known that we will need more people. It would be nice to have a few people that were assigned to the different regs.
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My opinions are not to be construed as legal advice.

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#9509 - 12/16/02 03:05 PM Re: Staff size?
Anonymous
Unregistered

I am surprise that regulators have not commented about your company having only one person managing AML/BSA and Compliance altogether, taking into consideration the size of your company.

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