CFPB-Ready Compliance Management Systems Have One Thing in Common: Backbone

Our very non-scientific answer, according to a recent webinar, was 43%. Yes, less than half of the HR and compliance personnel who attended Demystifying Your Compliance Program: What Your Financial Partners Are Looking For said they were confident that their organization’s CMS would stand up to CFPB scrutiny.

Naturally, we had a follow-up question: How are you managing your fair lending compliance program today?

We’ve written before about the drawbacks of paper, spreadsheets and emails—and the inaccuracies and gaps in these old-school systems should be apparent to anyone who works in compliance—but what about the multiple-systems approach? That one is tough to define, we found out. Our 39% gave numerous, differing responses when we asked them for details.

Are these the same people who responded “yes” to our previous question? My guess is that a few of them may be. But I sense that the likely answer is that many of the multiple-systems respondents fall into the “I don’t know” category. Because if you’re managing compliance by hand, via spreadsheet or paper, you probably either think you’re infallible or you already know your CMS doesn’t cut it.

However, if you’re taking a scattershot approach—delivering trainings with a learning management system, following up sometimes through email and sometimes in person, and leaving it up to various teams and departments to figure things out for themselves—you have little to no idea what’s going on and what needs to be fixed.