Building a Compliance Management System (CMS), Where Do I Start?
Last week Complí held our most highly attended webinar of the year, CFPB Enforcement – What Your Dealership Needs to Know. The main question on most dealer’s minds was “how do I build a Compliance Management System (CMS)?” As the CFPB continues to drive this expectation in the finance industry and their 3rd parties (that’s you auto dealers), there are more questions now than ever about how to achieve auto dealer compliance under the new rules.
“Can’t you just give me a checklist?”
Everyone wants a quick fix on this issue, which is the complete opposite behavior the regulators are trying to drive. Rather than trying to implement something in a few days so you can check “CMS” off your to-do list, doing it properly means time and strategic investment. Creating and implementing a Compliance Management System correctly means dealerships are going to need a 12-24 month strategic initiative to build the program. Dealers need to build business processes that will become part of their day to day operations for now and ever more, not look for the easy answer.
The Law Says…
When looking at the laws that you have to include for your CMS program, start at the Federal level. We are talking about Federal regulation here, so you should expect that an investigative demand from the FTC or CFPB will center on Federal Law. If you are unsure of the Federal Laws that impact your auto dealer compliance and would like to speak with a Compli expert on this, please reach out to us and we can help.
Answer the following question: do I have policies and procedures in place to address the Federal laws that impact my dealership? If the answer is “no” or “I’m not sure” you now have the first to-do for building out your CMS.