I just spoke to a friend at another lending institution. He is the compliance officer......he also does the consumer and RE lending in the office. Isn't there a conflict there?
Alot of small community bankers wear multiple hats. I know some bankers who are lenders and also hold the compliance officer hat. I don't think it is a conflict of interest as long as the CO is not auditing. I would think they would have a seperate auditor or outsource an annual audit for compliance.
I am a RE lender, commercial lender, compliance officer, auditor, BSA officer, etc etc etc...happens a lot in a smaller bank. I don't audit my own files for good practice, I have the assistant compliance officer do that.