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Outsourcing for Compliance Officer Function

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Question: 
We are a small community bank with $250 million in assets. We have lost our compliance officer again. Unfortunately, we can't justify a full time position for this. Do you know if banks are outsourcing this function and if so, where do I look to find the firms who offer this service?
Answer: 

"Compliance officer" means something different to every bank, but you are wise to look at two needs -- not just a replacement of one person who wore several hats. Simply put, the job breaks down to: a) ounces of prevention, and b) pounds of cure. It's relatively easy to outsource the "diagnose and cure" function (because it's basically a type of audit.) Unfortunately, by the time problems are discovered through file reviews (etc.), the horse is already out of the barn. The "prevention" function will be harder to outsource. This is the part of the "compliance officer" job that teams the "compliance officer" with line and staff officers who are developing new products, selecting and implementing new point-of-sale software (like loan doc systems), and otherwise growing the bank. Someone needs to provide the regulatory expertise to keep the line, staff, and marketing people out of trouble. This part of the "compliance officer" function will have as its motto: "It's always cheaper to do it right the first time."

First published on 10/03/2021

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