Eight Things a Compliance Officer Should Focus on in 2019

5. Eliminate Exceptions

Speaking of terribly catchy pop songs – Bye, Bye, Bye… to exceptions! Exceptions are okay…until they become the rule. I know that you want friends at work and a table to sit at when you go to the breakroom for lunch, but sometimes you have to be the bad guy. Exceptions should not become an excuse. They aren’t an allowance to go around the policy. They should be only used in times where it is a true anomaly and something you could not have excepted to encounter when authoring the policy. Take a close look at exceptions across the organization. Let them help drive your policy and process revision schedule as well as training schedule for the year.

6. Do a culture check

Look, I know writing policy and procedures is the joy of your life. You think about it on the evenings and the weekends and it just fills your cup. I get it – you’re a compliance officer. Have you ever stopped to think about what happens after you release that masterpiece into the wild?

Change! It should affect change! Words on paper do nothing to help you manage your program and mitigate compliance risk. Do you know how that change happens? People and systems…and you need people to work your systems. So it comes down to people. Your people have to make it happen. Their day-to-day work activities can either open you up to undue risk or fully mitigate any risks you may be facing. The best workers are happy workers. Here at Abrigo, we see people as the key to success, and you should too. Monitor employee satisfaction qualitatively and quantitatively to ensure you are properly mitigating conduct risk in your organization. Your exceptions tracking and finding remediation plan will thank you.

7. Set a cadence with marketing

Do you remember that one time there was a new product code in the system and the marketing campaign hit the internet, but the compliance department had no idea a new product was introduced? No? Good – that means you’re killing it! If this has happened to you, you need to open the communication with marketing to ensure it doesn’t happen again. You should have a seat at the table when marketing is discussing new products and services, even in the infancy stages. You are the key player for identifying potential compliance risks that these new products and services can introduce to your institution. If you don’t currently have a seat at the table, squeeze in a chair! Put some time on the marketing leader’s calendar, explain the criticality of compliance within product and marketing, and make a new friend. You won’t regret it!

8. Face Your Findings Remediation

Every institution should have a matured and well-implemented findings remediation process for audit and regulatory findings. If not, it is time to play catch up. Findings remediation should be a formal process with participation and buy-in from all business units and risk management functions. Progress should be monitored and measured with results communicated to senior management, executive committees, and the Board, as appropriate. I know that sometimes it feels like you're airing your dirty laundry, but it is all for the greater good. A clean audit may mean that you need new auditors. There are always new and emerging accepted practices, and these findings are how you grow and develop your program.

If you need help with achieving or implementing any of these eight steps, we’re here to help. Our advisory services team can help with any short or long-term projects at your institution.