ONE OF THE KEYS to being a successful in-house banking counsel is to have an effective and up-to-date compliance program. As an in-house counsel, one should either supervise or coordinate with the chief compliance officer on recent compliance developments such as the USA Patriot Act of 2001.[1]�
According to the Deloitte & Touche Top 1,000 U.S. Companies Corporate Compliance Survey,[2]� over 85 percent of the commercial banks responding have a chief compliance officer. The other 15 percent registered no response to this question. Further, all of these respondents state that these positions are full time. This is the highest response rate for any industry surveyed.[3]� The reason is that the importance and complexity of compliance with laws and regulations goes to the very ability of the bank to operate. Without strict compliance, the bank could be in jeopardy of losing its license and ceasing to operate. Thus, there is a need for a full-time compliance officer. Further, it is essential that in-house counsel closely coordinate with the compliance officer in order to create an effective program.
