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#30108 - 08/29/02 06:23 PM Consumer only or Also Safety and Soundness
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Just intereseted to know how many compliance professionals deal strictly with consumer compliance regs (with the exception of BSA)and how many deal with both consumer compliance regs and safety and soundness.
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General Discussion
#30109 - 08/29/02 08:03 PM Re: Consumer only or Also Safety and Soundness
BrendaW Offline
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BrendaW
Joined: Jun 2001
Posts: 233
Texas
I am in the Risk Management Department which is divided out by Internal Audit, Compliance and Loan Review. I do the compliance and only handle safety and soundness as it applies to BSA. Our Loan review people deal with the safety and soundness issues. Internal Audit deals with some of it as well....
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#30110 - 08/29/02 08:09 PM Re: Consumer only or Also Safety and Soundness
Michelle D Offline
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Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
I'm the risk management department which includes internal audit. I do both consumer compliance and a great deal of safety and soundness work - as in the compliance world - it's a lot of intrepretation work, writing comment letters etc.
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#30111 - 08/29/02 08:33 PM Re: Consumer only or Also Safety and Soundness
OnTheEdge Offline
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Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Would you mind stating your asset size and the number of branches within your institution?
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#30112 - 08/29/02 08:52 PM Re: Consumer only or Also Safety and Soundness
Walleye Woman Offline
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Walleye Woman
Joined: Jul 2002
Posts: 832
I am the Compliance Officer/Internal Auditor. I am from a small bank, $160mm, and used to be able to handle both duties. With all the new regulations I'm finding it is extremely difficult to get any auditing done. I'm so busy working on new policies and checking up on customers, not to mention working in the annual compliance reviews.
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#30113 - 08/29/02 09:12 PM Re: Consumer only or Also Safety and Soundness
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Compliance and Safety & Soundness is divided between 2 departments. (Asset size $417,000,000) Compliance (including BSA) is a one woman department, while Internal Audit does safety & soundness with a department of 4. The Compliance department performs a minimum of 26 different audits per 18 month cycle. (Core audits are performed annually) Day to Day compliance is assigned to Responsible Officers, who must answer to any compliance audit deficiencies.
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#30114 - 08/29/02 09:15 PM Re: Consumer only or Also Safety and Soundness
BrendaW Offline
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BrendaW
Joined: Jun 2001
Posts: 233
Texas
My bank has 19 branches and asset size of >$500 million. Our department cross trains so I dabble in it as well.

Comment Letters???? who has time for those....if I just managed I would be able to....but I manage, audit, and assess risk....plus CRA duties for a large bank....
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#30115 - 08/29/02 09:35 PM Re: Consumer only or Also Safety and Soundness
Anonymous
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An interesting aspect of the split of responsibility is how the FDIC includes BSA and Privacy issues/regulations within the Safety and Soundness examination, versus the separate FDIC Compliance examination. Within our recent Safety and Soundness exam, Privacy was a real big deal!

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#30116 - 08/30/02 12:19 PM Re: Consumer only or Also Safety and Soundness
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Yeah, and non-deposit stuff is in compliance. That has never made much sense to me. They were looking at giving BSA/Money Laundering back to compliance but I think that has been put on the back burner till after the reorg stuff settles down.
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#30117 - 08/30/02 12:43 PM Re: Consumer only or Also Safety and Soundness
Nanwa Offline
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Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
Sense? You expect regulators to make sense? Most regulations defy logic!

Live long and prosper....
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#30118 - 08/30/02 12:49 PM Re: Consumer only or Also Safety and Soundness
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
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the sandy shore
In reply to:

You expect regulators to make sense? Most regulations defy logic




Hey, hey, now - let's remember who WRITES the regulations - Congress. It's not the poor examiners' fault that they're poorly written.

And on that note, I'd like to have a word with the .... people.... in Georgia who wrote their fair lending law!!
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#30119 - 08/30/02 12:49 PM Re: Consumer only or Also Safety and Soundness
BankerMama Offline
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BankerMama
Joined: Jun 2001
Posts: 1,543
Exactly!!!
A Safety and Soundness exam is just coming to a close here. Of course they did BSA,but they also did Privacy/Information Security Program because "they don't know yet if it will be on the S&S side or the compliance side of the exam". And believe it or not, they even wanted to see an example of consumer compliance audits.......as part of the loan review!? That one took me by surprise for sure.

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#30120 - 08/30/02 01:12 PM Re: Consumer only or Also Safety and Soundness
Nanwa Offline
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Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
Yeah, Congress writes the laws, but the Regional Office interprets them! We in the field would try to be reasonable and logical, then the report went to the RO, and we would get phone calls to change things. I finally said "Fine, I will change it to the way you want, but take my name off of the exam." I mean, the "ivory tower people" (RO review examiners) weren't there, and hadn't examined banks in years!

Now you know why I am a banker, not an examiner anymore!
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#30121 - 08/30/02 01:36 PM Re: Consumer only or Also Safety and Soundness
E.E.G.B Offline
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E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Our REs (including me) were all just out of the field - max time out was maybe 3 years? So I think at least in this region it was more reasonable. Of course the examiners whose reports I edited may feel differently....
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#30122 - 08/30/02 02:36 PM Re: Consumer only or Also Safety and Soundness
Nanwa Offline
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Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
I worked in Chicago - some of the review examiners were in the RO and out of the field for over 15 years.

I worked in Dallas years ago when Mcorp closed. I really like your part of the country!
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