Compliance Program Topic Center

Without compliance, a compliance management system is, well, a “management system”—which means nothing but overhead.

The Nuts and Bolts of Your
Compliance Management System

Certainly, a CMS should encompass more than just workforce processes, training modules, and activities, but make no mistake: these elements are fundamental, and shouldn’t be treated as an afterthought.

A compliance program involves the obvious things that come to mind when one hears the word “compliance”: policies, procedures, trainings, guidelines, and so on. Think of it as the nuts and bolts of your CMS. When your compliance program functions properly, the whole CMS operates smoothly, efficiently, and effectively. When your compliance program needs work, it’s like a rusty set of gears or an engine running without oil: it slows down the rest of your CMS and can bring your organization to a grinding halt.

A CMS contains 4 areas of focus:
Mouse over each area to learn more.

Download theCompliance Initiative Worksheet

A well-planned, well-implemented, and well-maintained compliance program…

  • prevents or reduces regulatory violations;
  • protect consumers from non-compliance and associated harms;
  • shields your organization from the risks of litigation, which negatively impact
    • revenue,
    • operational focus,
    • and brand reputation;
  • and helps your organization attract and retain customers.

To establish a well-oiled compliance program, you’ll need to answer these questions:

What policies
and trainings
do we need?

While every organization has unique compliance needs, members of the financial services industry need to abide by a specific set of laws and regulations. According to the CFPB, every Fair Lending compliance programs should cover the following:

  • Unfair, deceptive, and abusive acts or practices (UDAAPs). According to the Consumer Financial Protection Bureau, an act or practice falls under UDAAP categorization when the act or practice “causes or is likely to cause substantial injury to consumers,” “the injury is not reasonably avoidable by consumers,” and “the injury is not outweighed by countervailing benefits to consumers or to competition.”
  • The Equal Credit Opportunity Act (ECOA). ECOA prohibits finance companies from making a determination of a consumer’s creditworthiness on the basis of a protected characteristic, such as race, gender, national origin, or marital status.
  • The Truth in Lending Act (TILA). TILA requires organizations that offer loans to disclose certain information, such as leasing provisions and credit terms, to consumers before lending money.
  • The Telephone Consumer Protection Act (TCPA). Under TCPA, lenders must obtain prior express written consent from customers to whom they intend to send text messages or make phone calls.
  • The Fair Credit Reporting Act (FCRA). FCRA establishes rules for ensuring fairness and privacy for consumers applying for a loan or line of credit.

A compliance program cannot address Fair Lending laws in the abstract. Each statute enumerated above includes subset of specific regulations that address a wide range of organizational processes:

  • disclosure of nonpublic personal information
  • information security
  • privacy and security practices of service providers
  • an identity theft prevention program
  • information sharing with consumer reporting agencies
  • advertising and marketing of consumer loans and leases
  • approval and denial of loans and leases
  • pricing for loans and leases
  • compliance training and related materials
  • document retention
See How It Works

Why is Automation so Important?

An automated compliance management system like Compligo removes the 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.

Recent Articles on Compliance Programs

Compliance programs are always a hot topic for our readers. Here’s the latest research and perspectives.

Compliance Program Resources

Study up on the topic be downloading these great resources.

Join our Newsletter

lightbulb-iconGet consumer lending tips, tools, and articles sent to your inbox weekly.

New Call-to-action
  • CMS University

    Enroll in CMS University today! Nobody likes a 1,500-page textbook. But, that’s the material regulators expect you to know about consumer lending compliance and building a ... [More]

  • CMS Blueprint eBook

    Building a solid Compliance Management System is no easy task. It’s a big, hairy, complicated beast. But an important one. Let’s demystify what the CFPB ... [More]

  • Compliance Program Blueprint

    Let’s demystify what the CFPB expects of your fair lending compliance program. You could read the CFPB’s 1559-page manual outlining what they expect from your ... [More]

  • CFPB Workshop: Implementing a Compliance Program

    Watch this webinar to learn how to implement an effective Compliance Program for tracking the distribution, attestation and storage of policies, procedures and training for ... [More]

Compli is a great platform that integrates every part of the business, from compliance to operations to HR.
Julie Kim
In-House Counsel & Compliance Officer / Sierra Credit Corp.
Compli offers a great, purpose-built platform that assigns, tracks and monitors any workforce compliance activity – not just training. The platform can help any organization rein in its compliance processes and execute them more efficiently, consistently, and effectively.
David Wentworth
Principal Analyst / Brandon Hall Group
Compliance has never been optional, but there are a lot of companies in the past who have operated that way. In light of recent events, compliance has really stepped up in the last few years, so we really have to make sure all of our bases are covered and make sure we're always in compliance at all times.
Andy Page
Director of Operations / Road Auto Finance
The training was pretty flawless. You know, I've dealt with a lot of different third party vendors as far as software, and they're usually not very fun to deal with. Compli was very, very good. I was honestly shocked about how easy it was. I just answered a few questions, and everybody over at Compli just kind of took it from there.
Andy Page
Director of Operations / Road Auto Finance
All my employees know what the rules are and they know where the boundaries are, and they know not to step out of bounds. So my capital source feels much more comfortable knowing that my employees know where out of bounds is.
Andy Page
Director of Operations / Road Auto Finance
All policies, procedures, training material, and personnel files are in a central location, and the search function makes it easy to find any file in the system.
Julie Kim
In-House Counsel & Compliance Officer / Sierra Credit Corp.
Compli eliminated inefficient internal processes and enabled us to focus on actual business matters.
Julie Kim
In-House Counsel & Compliance Officer / Sierra Credit Corp.


Send this to friend