If you have not had a compliance exam in the last two years, be prepared for increased scrutiny of your CMS. Here are some tips:
Annual approval by the board,
Budget specific to compliance and determine how much is spent per employee (national average is edging up to $2,000 per employee) Take total budget, divide by number of employees, be sure to include the cost of all compliance training.
Consider a checklist to be used to qualify the Compliance Officer and/or staff. I will gladly provide a sample if requested.
Written program, including a tentative audit schedule. Use the word tentative, so you are not held exactly to the schedule, we all know things come up. If not tentative, would need changes approved by the board……
Incorporate the program with all other bank policies. This program does not just belong to compliance. It is an enterprise wide program.
Consider an org chart for the compliance department. Outline who does what and be specific, helps all parties understand the work flow and expectations.
I recommend internal audit, CRA and BSA report under the Compliance umbrella. Think about it, the work flow and responsibility just makes sense. Compliance can assist with the internal audit and BSA monitoring of loan files and new accounts, helps create efficiency. CRA is examined with Compliance, so that one is an easy jump.
Hope this helps and you find yourself an improved compliance rating.