In Bankrate, one of the web sites I use for research, an article appeared this week that really caught my eye. The purpose of the web page is information for consumers. The article pointed out that consumers of financial institutions really have no clue about Check 21 and its affect on them.
I found that not surprising, but what does bother me is the fact that not too many financial institutions employees know enough about it yet either.
Isn't it an anomaly that in a business as closely regulated as ours, where communication of "the rules" is so important in order for us to stay "in compliance" that training is the last thing to be granted a budget, and the first to be cut? You'd think the training function would be primary - a basic function. But I've gone to teach compliance and security sessions for financial institutions that have been in business ten and more years and mine was the very first formal training session they ever had. How do they train their front line?
We recently received news of a very large bank that was fined millions of dollars because of Bank Secrecy Act violations. It isn't that BSA hasn't been around for years. But we turn over personnel, who, in their first days on the job have no idea that the requirements for BSA compliance even exist, let alone know what to watch for.
When I'm teaching at conferences and I talk about risk assessment and questions come from attendees, I realize these security and compliance officers know what the risks are. They're looking to fine-tune their systems. It's the old adage of "preaching to the choir." These are not the folks that need to know about risks - they already know! It's the people handling the opening of accounts and handling the transactions on the front line that need to know. And they're not getting the message.
All of this is one of the reasons George and I started this newsletter fourteen years ago. If you look at our mission and goal on the back page of this newsletter, you'll see the first and foremost purpose is "...to keep front line and operations personnel up-to-date on regulatory and compliance issues and industry related techniques." But as one banker pointed out to Congress during the hearing on regulatory burden, there were 801 'final rules' handed to our industry since 1989 when the Financial institutions Reform, Recovery and Enforcement Act (FIRREA) was passed. 801! That's more than we can pack in an eight page newsletter.
We're here to help. But please don't depend on circulating copies of the Bankers' Hotline and Compliance Action to do all your training for you. Communication to your front line is critical. See if you can't get a budget for training.
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