Compliance Department Structure

Posted By: Random

Compliance Department Structure - 03/28/11 07:19 PM

I am looking for feedback on how to structure a compliance department of a 500 mil bank with 7 branches? Should there be just a compliance officer that handles all of the officer functions and reviews or should there be an officer and an auditor? Would anyone suggest outsourcing reviews? Thanks!
Posted By: P*Q

Re: Compliance Department Structure - 03/28/11 07:25 PM

We have 5 branches and $400m deposits. I'm the Compliance Officer with 2 direct reports. One who handles BSA and one who does loan stuff. I do misc. regs, serve as BSA Officer, conduct internal reviews, manage risk and assessments. We have an external audit firm perform compliance audits annually to confirm our internal monitoring is working properly.So far so good!
Posted By: fun grandma

Re: Compliance Department Structure - 03/28/11 09:28 PM

We have 7 branches and $360m bank. I conduct internal loan reviews, regs and policies for loan/deposit area. I also am the main contact person for the examiners.
Another person handles the BSA and operations.
Can get stressful, especially with all the new/updating regs in the loan area.
Does work, but can get frantic!
Posted By: RR Joker

Re: Compliance Department Structure - 03/29/11 01:01 PM

At the 500mil mark, we separated Audit and Compliance. I am the sole CO. Compliance reviews were transferred to Audit so that I could concentrate more on the 'front end' of things without any conflicts.

Now we are about 1B and I still am the sole CO and IAM. Audits are still handled through the Audit Department, however.
Posted By: AFaquir

Re: Compliance Department Structure - 03/29/11 01:24 PM

At the moment I'm the compliance officer be all and end all. We had a loosely assigned division of duties prior to me taking on the role with roughly 2 people tagging in and out of compliance one doing BSA/Ops and one on the loan side with the CO at the top of that structure. We are 4 full and 2 half branches with close to $250M.

So far its working fine, but as someone mentioned above it can get pretty hectic so you gotta pace yourself and have a little faith that compliance is being upheld in practice without your masterful hands being on everything.
Posted By: Tater

Re: Compliance Department Structure - 03/29/11 03:45 PM

Originally Posted By: AFaquir
have a little faith that compliance is being upheld in practice without your masterful hands being on everything.



Love it! So hard to give up control.......but once you can, it's a wonderful feeling smile
Posted By: Bullseye

Re: Compliance Department Structure - 03/29/11 07:46 PM

Originally Posted By: Pizza Queen
We have 5 branches and $400m deposits. I'm the Compliance Officer with 2 direct reports. One who handles BSA and one who does loan stuff. I do misc. regs, serve as BSA Officer, conduct internal reviews, manage risk and assessments. We have an external audit firm perform compliance audits annually to confirm our internal monitoring is working properly.So far so good!


Almost ditto Pizza here...but we are about $600M in assets with 7 branches.
Posted By: Richard Insley

Re: Compliance Department Structure - 03/30/11 01:59 PM

Originally Posted By: RR joker
we separated Audit and Compliance...Compliance reviews were transferred to Audit so that I could concentrate more on the 'front end' of things without any conflicts.

Very wise decisions. An ounce of prevention is worth a pound of cure. Well-designed products and delivery processes are more likely to be in compliance and stay in compliance, and it's always cheaper to do it right the first time.