Thread Starter: BrianC
Title: Re: BSA Department Size
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Asset size is not the sole driving factor to the number of FTEs a department may need. You must also consider the volume of higher-risk customers and the types of higher-risk products and services you offer.
I had a client that was a small bank that decided to specialize in non-bank financial institutions because of the opportunity for non-interest income. Since they were only $150 million in assets, they felt that they were good with a single BSA Officer to handle everything. As a result, examiners found that that one person was way behind on EDD which resulted in a consent order. Even at $150 in assets, they now have a department of four to manage the workload of EDD, CTRs, monitoring alerts, etc. for all their high-risk customers.
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