Responsible Individual / BSA Officer

Under NCUA regulation § 748.2(c)(3), FICUs are required to designate an individual responsible for coordinating and monitoring day-to-day BSA compliance. This individual is generally referred to as the BSA officer or BSA compliance officer. The board of directors ensures the BSA officer has the knowledge, authority, independence, and resources to fulfill the responsibilities of this position.

In smaller credit unions, the BSA officer is likely the credit union manager or assistant manager. In larger credit unions, the BSA officer is generally the manager of the BSA or compliance department. Scheduling an entrance meeting with the BSA officer will help the examiner gain an early understanding of the credit union's compliance program.

Examiners verify that the credit union’s board of directors has designated an individual responsible for the overall compliance program and that the individual is qualified. Examiners review reports to the board of directors and senior management regarding the status of ongoing compliance and pertinent BSA-related information, including the required notification of SAR filings. Examiners confirm the BSA compliance officer has the authority, independence, and access to resources.

For more information, see the BSA Compliance Officer section of the FFIEC BSA/AML Examination Manual.

Last updated on February 02, 2023