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#595407 - 08/08/06 10:24 PM BSA job description & "procedure"
Darkhorse Offline
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Darkhorse
Joined: Nov 2004
Posts: 501
out of my mind
Hi all! My CEO just went to some kind of meeting today and came back asking for both a stand alone BSA Job Description and "BSA Procedure." We don't have a stand alone BSA Officer (don't we wish!) and I can't even begin to think about all the procedures that BSA affects. Does anyone have anything they'd be willing to share with me? Exam in 13 days . . .

Please PM me if you do. Thank you so much!!!!
Last edited by Darkhorse; 08/09/06 06:55 PM.
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#595408 - 08/08/06 11:26 PM Re: BSA job description & "procedure"
Dip Offline
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Dip
Joined: Mar 2005
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San Diego, CA
is your CFO possibly confused? i mean, you have to have a BSA Officer, but that person may also have another position. and you have to have a BSA program, which is really just a BSA policy covering compliance, training, reporting, and monitoring.
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#595409 - 08/09/06 02:21 PM Re: BSA job description & "procedure"
MagicCity Offline

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MagicCity
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Fort Lauderdale, Florida

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#595410 - 08/09/06 06:57 PM Re: BSA job description & "procedure"
Darkhorse Offline
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Darkhorse
Joined: Nov 2004
Posts: 501
out of my mind
Oops, that should have said my CEO and yes . . . she thinks everything just magically happens by spreading a little fairy dust around

I told my boss (the named BSA Officer, though another officer & I do the daily stuff) that we should just give her the FFIEC exam manual - since if they are testing it, we should be doing it. That should cover all our procedural requirements, right?
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#595411 - 08/09/06 09:14 PM Re: BSA job description & "procedure"
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
How have you gotten through audits and examinations in the past?

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#595412 - 08/10/06 03:35 PM Re: BSA job description & "procedure"
Darkhorse Offline
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Darkhorse
Joined: Nov 2004
Posts: 501
out of my mind
My CEO's version? Because our system is great, no one is stressed out/burned out and it all works beautifully . . .

The reality . . . I work six and seven day work weeks and continue to fall further and further behind . . . But I have an incredible Office Manager in a nearby location who has been helping me to try to keep me from drowning. I can't tell you how much I appreciate her! I would have lost my last remaining slice of sanity (small as it is) without her.

As far as procedures . . . we have a BSA/AML policy (and CIP, and . . . ) but honestly, there isn't just one single BSA procedure . . . it's like information security - it touches (or should touch) every area. Every procedure should be mindful of certain regs, like BSA.
Last edited by Darkhorse; 08/10/06 03:38 PM.
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#595413 - 08/10/06 05:19 PM Re: BSA job description & "procedure"
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
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Toano, VA
Quote:

As far as procedures . . . we have a BSA/AML policy (and CIP, and . . . ) but honestly, there isn't just one single BSA procedure . . . it's like information security - it touches (or should touch) every area. Every procedure should be mindful of certain regs, like BSA.



This is a perfect answer for your CEO (and for your regulator.) It underscores the need for her to keep the pressure on all of her business managers to stay on top of the BSA procedures developed within their respective business lines.
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