BSA Officer dedicated time

Posted By: piggybanker

BSA Officer dedicated time - 05/11/15 01:55 PM

Right now in our Bank the BSA Officer also servies as the Compliance Officer. His complaint is with all the new Loan changes etc. He cannot dedicate the time he needs to BSA. We have been told in trainings you need to be able to dedicate 70 % of your time to BSA and with Compliance audits he cannot do this. Do most banks have these as two separate positions our banks asset size is 146 million? Argument from senior management is we are not big enough for these two jobs to be separated. I need some backup statistics...
Posted By: NSF, CRCM

Re: BSA Officer dedicated time - 05/11/15 02:02 PM

We do at our institution. We have a 3 person department with a BSA Officer, Compliance Officer and an Assistant Compliance Officer.
Posted By: bcompliance

Re: BSA Officer dedicated time - 05/11/15 02:04 PM

I am the BSA Officer and Compliance Officer. We have an Internal Auditor as well, however he is set to retire at any moment so I have been doing many of these also.
Posted By: Matt_B

Re: BSA Officer dedicated time - 05/11/15 02:20 PM

$350 million, I'm compliance, BSA, security, and an assortment of other things. Nothing (except frustration) can consume 70% of my time. BSA consumes a good chunk of time some days, and others very little, but we're in a fairly low risk area.

You won't find 70% as a requirement anywhere. Go by your risk assessments, devote the time needed to run your program, no level of comparing to other financials will tell you if you've got it right or not, there are just too many variables to consider. But if the BSA duties fall through the cracks, you have a few late CTR filings, or something missed... you'll end up regretting not giving it the time and attention it needs, and it may be significantly more than a polite suggestion smile
Posted By: Skittles

Re: BSA Officer dedicated time - 05/11/15 02:26 PM

We are also separate - we have a BSA Officer, Compliance Officer (me), and Assistant Compliance Officer. We are approximately $250 Million.
Posted By: Elwood P. Dowd

Re: BSA Officer dedicated time - 05/11/15 02:30 PM

Quote:
We have been told in trainings you need to be able to dedicate 70 % of your time to BSA...


Actually, it's 62.6%. Really, quoting any percentage is ridiculous. As Matt says, there are simply too many variables ranging from the size of your bank, it's clientele, the complexity of its lending products, etc...

All I can say is that there is simply too much to know to be competent with both subjects at the same time. I've only known a couple trainers who could do it, but remember, all the trainer has to do is remember the material, he or she does not have to do the job too.

My apologies to anyone who does both and does them well, but we clearly have not met.

P.S. rlcarey could do it. Hire him. wink
Posted By: jmcd501

Re: BSA Officer dedicated time - 05/11/15 03:00 PM

We have seperate BSA Officer and Compliance Officer and also a compliance assistant. $128mil.
Posted By: Matt_B

Re: BSA Officer dedicated time - 05/11/15 03:06 PM

Originally Posted By Ken_Pegasus
P.S. rlcarey could do it. Hire him. wink


He'd just cut loose any customer that was a BSA issue, making that job just a simple CTR filing position! In fact... maybe I should get him in here! It'd sure make my life easier.

I won't take any offense at the dual role comments, I'm very well aware of the areas that fall through the cracks here, and if we had automated systems for flagging suspicious activity and such, I'm pretty sure I could do BSA full time.
Posted By: ItNeverEnds CRCM

Re: BSA Officer dedicated time - 05/11/15 03:52 PM

We're about $180 million, one location. I am the Compliance Officer, BSA Officer, Security Officer and oversight of Operations, among a lot of other fun stuff.

As Matt states a lot depends on your risk. What types of products and services you offer, the types of customers, etc. If you don't bank MSBs or have many high risk businesses, BSA doesn't take up a lot of time. Also, how much is your BSA officer expected to do as far as reports, CTRs, SARs, monitoring, etc, are any of those jobs "farmed out" = are others doing them with the BSA Officer just having oversight?

Same goes for Compliance, are others doing monitoring, drafting procedures and such so that your BSA/Compliance Officer is overseeing the process? If I had to do a lot of compliance monitoring and draft all the procedures, as well as do all the daily BSA stuff, no, there's no way I could do it all. But the bank doesn't pay me to be the person that does all the daily stuff, they pay me for my brain grin I'm the one that directs, manages, oversees, etc.

I'd take a look at how your processes are set up and the roles each person plays. If your BSA/Compliance Officer is bogged down in daily duties, that's the first thing I'd look at fixing.
Posted By: banker1976

Re: BSA Officer dedicated time - 05/12/15 12:10 PM

We have: BSA Officer, Deposit Compliance Officer, Lending Compliance Officer. $450 million.
Posted By: JWills, CRCM

Re: BSA Officer dedicated time - 05/12/15 12:51 PM

We are $232 million. We have a BSA Officer, a Compliance Officer (me), and just this past December have added another to our department who is now the deposit Compliance Officer.
Posted By: ahkcompliance

Re: BSA Officer dedicated time - 05/12/15 01:40 PM

We are about $200 million and have a separate BSA Officer and Compliance Officer. Our BSA Officer will be retiring in the next year and those duties will then fall onto me along with a few others. The daily duties of the BSA Officer are actually farmed out to other areas. The head person over the tellers actually files the CTRs for us while the BSA Officer just has the oversight.

As others have said it is hard to compare. It will all go back to your risk assessment. For some banks it may make sense to combine all into one position but for others may need them separated.
Posted By: edAudit

Re: BSA Officer dedicated time - 05/12/15 01:45 PM

Where is Randy

This is really comparing apples to Motorhomes.

a small town bank in a small community in a low risk state would have a much different requirement than a small (or med or large) bank in Miami.
Posted By: Compl101TX

Re: BSA Officer dedicated time - 05/12/15 01:56 PM

This thread reminds me of the salary comparison one. You just can't compare!
Posted By: ACBbank

Re: BSA Officer dedicated time - 05/12/15 04:35 PM

I was thinking the same thing Ed. Randy is clearly slacking smile
Posted By: Rudy06

Re: BSA Officer dedicated time - 05/14/15 02:12 PM

I think it depends on what the staffing levels on each side are. We are a $12B institution and up until recently the compliance and bsa officer were the same person. Both areas had a manager that managed the day to day operations of the department while the CCO managed budgets, executive oversight, etc. I think the new way it's split out works better but we functioned effectively for a long time with it as one person.
Posted By: Sunshine Lady

Re: BSA Officer dedicated time - 05/14/15 02:56 PM

We have a compliance officer and a BSA officer. Our examiner made the recommendation that the jobs needed to be separate and it has made a great difference and lifted a lot of the BSA duties from our Compliance officer. She is my back-up, but I agree, right now she is getting ready for the new loan disclosure requirement changes and a compliance exam. In our case, it made sense and it works. We are a 230 million.