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Monitoring Loan Activity

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Question: 
Our internal auditor was asking how we monitor loan activity. We are not sure if the BSA person is responsible or if the loan department is responsible. Can anyone give me guidelines?
Answer: 

There is no standard approach; it will vary among institutions, but it is likely to be the BSA Officer or department that does the scut work. The following language was included in some materials I used in training on revising policies and procedures. Although it is the approach I would take, I'm not advocating its use, only using it to demonstrate that your policy could answer the question:

The Bank Secrecy Act (BSA) Officer is responsible for monitoring BSA, AML and OFAC compliance efforts and assuring that critical compliance related procedures are reduced to writing. However, individual department heads are responsible for their area’s development of those compliance procedures and their specific compliance with both law and bank policy.

First published on BankersOnline.com 12/07/09

First published on 12/07/2009

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