I am the bank's Auditor and Compliance Officer. I have difficulty doing compliance audits when I am the one that does training, helps develop procedure, etc. It appears that I am auditing myself in some aspects which I don't feel is being impartial. Does anyone deal with this and do you have any suggestions?

I am the same at my bank. I do not develop pol/procedures but provide information so that the appropriate dept can develop but only as they pertain to federal/state regulations. I am responsible for training but we use ABA's free compliance training. Dept. managers are responsible for training on internal procedures.

Thanks Kahola. What is the ABA's free compliance training? Is it online training?

Do you have to be a member to access the ABA's free compliance training?

Currently I do compliance training, write policy & procedures, do all compliance monitoring/reviewing. Because we are a small community bank I think we get by with examiners. At my last bank, we were much larger and still got by this way. At the last exam before leaving, they were told to separate the two functions.

ABA does offer free online compliance training to its Members. We use it as well.

OnTheEdge hit the nail on the head. If you are small, you can usually get away with it as long as the bank is not exhibiting any real problems. I know I did at a small organization, but as you grow, you will see more and more pressure from the regulators to separate them out.