I was just wondering how many auditors also wear the compliance hat in their organization. I do, but i don't have any operational responsibilities. I monitor and communicate reg changes, hold compliance training and help address compliance issues but management has overall responsibility for compliance including conducting compliance self-monitoring programs. I also audit management for compliance with regs and now some are questioning my independence from a pure organizational perspective. Does anyone know of any regulatory guidance or opinion letters on this topic. I enjoy doing both and would rather not give up either job.

There was a similar thread recently.

I am corporate auditor and also test compliance. I really don't see a big difference from testing asset/liability managment vs. Reg E. There is a separate compliance officer who is in charge of writing policy, but most all questions come to me. I think I am independent?? A question has recently come up as to whether I can advise on policy or if that would take away from my independence.

I believe this is quite common. Many of us wear that Internal Audit/Compliance Officer hat. I do. I guess I am wondering why are some questioning your independence between the two? Especially if you do not have any operational responsibilities? Speaking purely from my own experience, in community banks where resources are limited I think a bank would be hard pressed to keep the auditor/compliance person to even those sole responsibilities. If you read these posts you see that not only do we do these, but we assist in CRA, BSA, Online banking, new product development, etc.. it simply cannot be helped and I would think that it might be unfortunate that if you have a sharp individual that you wouldnt utilize that individual elsewhere, barring circumstances where there could be a conflict of interest (i.e. writing policies...and how many auditors/compliance people do we have that will admit that even they have written a policy or two? ) Anyway, don't feel alone. These threads are a great place to come to find out truly that others walk in our shoes every day. Good luck.