3 Questions: What to Ask to Make Sure Your Compliance Program Does What It’s Supposed to Do

3 Questions: What to Ask to Make Sure Your Compliance Program Does What It’s Supposed to Do

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Last week, we showed you the difference between a compliance management system and a “management system”—i.e. overhead masquerading as compliance. This week, we’re going to teach you how to develop the former, through 3 fundamental questions.

Ready, set, go!

Who is responsible for what?

Once you have mapped out all of the laws your organization must comply with, you will need to define roles at your organization and assigned the appropriate policies and trainings to each role. Your loan originators and underwriters, for instance, will need to undergo training on UDAAP and ECOA policies, while sales and marketing personnel should follow TCPA regulations, and your collections team will need to understand fair debt collection practices.

It’s a lot to manage, regardless of your organization’s size and composition. With so much role-specific information to absorb and become competent in—on top of the daily rigors of doing the job—no one person at your organization may be able to hold onto all the regulatory facts that pertain to your business. Every employee and department may have deep knowledge of their individual compliance responsibilities, but an incomplete understanding of the full CMS. A compliance program ensures that, in a multi-dimensional organization made up of different audiences who have different compliance needs, every incomplete piece fits together to form a cohesive picture.

How do staff stay current on changes to laws and regulations?

In the consumer finance sector, compliance is not just a matter of training employees once, but keeping them apprised of ongoing updates to the law. The only constant is change—so how do you make certain your staff is staying current on the latest developments in a convoluted, dynamic, and ever-evolving regulatory environment?

Your best bet is to rely on subject matter experts—be they compliance personnel within your organization, or external consultants—to take on the burden of writing and reviewing your policies. But expertise can only go so far. Once you’re confident your policies are up to date, you need an efficient way to distribute them, as well as a means to ensure your team reads and understand the policies.

The only surefire way to do all of this is with an automated compliance management system. Consider the risks of handling ongoing compliance updates through manual processes:

  1. A compliance manager, HR administrator, or attorney might miss an important agency bulletin or learn of it too late.

  2. Certain personnel, departments, and third-parties may engage in outdated practices due to information silos.

  3. Without an automated system sending notifications and reminders, employees might neglect or forget to complete trainings on regulatory updates.

  4. Managers and supervisors may not understand what compliance data to collect, or how frequently, and could struggle to produce timely, relevant reports…

  5. …and, as a result, the CEO and board may lack top-level oversight of the organization’s overall compliance.

How do you operationalize your program?

Automation allows your organization to conduct compliance the way regulators demand you do: thoroughly, securely, and without delay. An automated CMS houses and organizes your policies, procedures, training materials, and supporting processes and forms. The CMS should automatically schedule, distribute, and track these activities through the various components of your workforce.

An automated CMS can streamline your compliance program by organizing and assigning compliance activities by role. For example, the system can be configured to manage and track all specific policies, procedures, and trainings assigned to employees in your collections department. You can set a schedule for each activity as well, so employees always know if they’re updated or behind on their responsibilities.

Because an automated CMS applies to roles—and not the individuals who occupy those roles—anyone can be plugged into the system, at any time, with a minimum of effort. Nothing slips through the cracks when organizational changes occur. As soon as a new employee is assigned a job title, role, and location, the system takes care of the rest. You no longer have to rely on a manager or supervisor to place the right stacks of paper on somebody’s desk, or to dig through file cabinets full of documents.

Why automation is so important.

An automated compliance management system removes all guesswork from your compliance program. First, it ensures your staff understand the policies and procedures that pertain to their roles. Second, it gives you the capability to assess the status of your organization and provide defensible proof of compliance to stakeholders and auditors whenever necessary.

Without a doubt, automated compliance management systems save time and money for the organizations that use them, but their true benefit is the confidence they instill in leadership: confidence that the organization is protected, confidence that your employees and contractors are working in unison, confidence that noncompliance will not interrupt your business’s continued growth.

For compliance, it’s what’s inside that counts. The right nuts and bolts will keep things running well—right now, and far into the future.

Toby Graham

Toby manages the marketing communications team here at Compli. She's on a quest to help people tell clear, fun stories that their audience can relate to. She's a HUGE sugar junkie...and usually starts wandering the halls looking for cookies around 3pm daily.

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