August 20, 2015 10:34 am

By, Cody Roberts

Every once in a while, compliance personnel get to look up over the trees and survey the broader landscape of compliance. I would suggest doing this by reviewing what others in the woods are doing around the country. Checking out the results of the 2015 ABA Survey of Institution Compliance Officers Report is a great place to start!

The following shows a brief overview of how the information was collected and collated:

  • The ABA collected information from February-March 2015 through a 70-question web-based survey
  • Respondents were Chief Compliance Officers and compliance professionals from 457 financial institutions
  • Major topics included:
    • General information about the institution
    • Information about the institution’s chief compliance officer
    • Information about the institution’s compliance structure
    • Compliance accountability
    • Compliance products and services
    • Risk management and the cost of non-compliance
    • Regulatory relations
    • Topical issues
    • Compensation
  • Much of the information was broken down by asset size categories (i.e., less than $100 million, $100 million to less than $500 million, $500 million to less than $1 billion, $1 billion to less than $10 billion and $10 billion or more).

While the 97-page report is well worth reading from cover to cover, below I highlight a few items I found noteworthy. Please note that a little over half of the respondents were less than $500 million in assets (the rest were well-dispersed among the other asset categories), while by supervisor about 60% of respondents were FDIC, about a quarter were OCC, about 10% were FRB and less than 3% were CFPB.

  • Chief Compliance Officers are becoming more specialized in compliance. Almost 90% of compliance officers have a compliance background, while previous jobs show about half were from bank ops, about a quarter each were from auditing and lending and around 6% were regulators.
  • About half of banks are seeing their separate compliance budgets increase when compared to last year. Budget increases of 10% or more are due mostly to changes in staff level, followed by regulatory burden, training costs, use of vendors/consultants and IT/computer systems.
  • Banks are reluctant to reach out to regulators. A little more than one-quarter of banks have contacted an agency field, district or Washington office to resolve issues. However, eight in ten banks expressed satisfactory resolution.
  • UDAP/UDAAP is being emphasized. Reviews at agency examinations occurred at about one-half of banks and the review occurrence increases with asset size.
  • Examiner information requests for examinations continue to confound bankers. The response to “all information requested is used” resulted in a ‘yes’ less than a quarter of the time, while “examiners clearly explain the need for the information” resulted in a ‘yes’ less than a fifth of the time. Some things never change.
  • Monitoring of social media or other websites for consumer comments about their bank is not being done by almost half of banks. This makes sense since examination review of the bank’s social media oversight and performance was not reviewed during more than half of exams.

For more information on this report, please visit, and sign in with your ABA password.