We have someone in compliance but we do not have a Compliance Officer. I thought I remembered reading somewhere that a Compliance Officer was a requirement.

I do not beleive you need a compliance officer. I think this depends on the structure of your bank. Someone in the organiation must have the accountablity for compliance.

Lori

You need a named BSA officer, CRA oficer, Security officer - which have the accountability.

IMO, like Lori mentioned the work can be handled by various departments and training/implementation outsourced.

I agree, for smaller banks that you may have someone in Deposit area that is responsible for their side and someone on Loan side responsible for their side.
Someone, or someone(s), must be identified as responsible but there is not a requirement for A Compliance Officer