Why We Do This?
It is easy to get bogged down in compliance. There are so many details, so many regulations, so many ways to make mistakes. Counting common violations, plugging holes, designing risk management programs all add up to overwhelm us from time to time - or often.
When feeling overwhelmed, we have choices. We can sit back, mope and seek comfort, we can do battle with the regulations or resistant staff, or we can put things into perspective. My vote is on putting things into perspective - while maintaining compliance, of course.
Fair lending laws may be one of the scariest compliance issues we face. They are unclear. They are difficult. They are both technical and broadly conceptual. And - most difficult of all - they take us outside of our comfort zone.
CRA is almost as scary. We operate under unclear instructions seeking unclear goals. The only certainty is the consequence of noncompliance. We have to go into neighborhoods where we don't feel comfortable and may not even feel safe. We have to teach people how to be customers. We have to take risks. We have to rethink our underwriting criteria and our business goals.
Many of us often wonder whether all this is necessary. Why, after all, should we work so hard to make things easy for others? What is this all about, anyway?
Sometimes an event gives us the perspective we need. Holidays, both religious and national, are a time for counting our blessings and looking for meaning in our lives. Recently, I received a Christmas card and note from my hairdresser which, more brightly than a shining star, showed me why we do all this compliance stuff.
She grew up in Vietnam during the protracted war years and came to this country as a very young woman. Her perspective on the United States is shaped by her experiences there and here where she started with nothing but the chance to work - hard. She is now a homeowner and a skilled professional with many loyal customers who, like me, have followed her through several moves.
In her Christmas note, she wrote: "I have so many things to be grateful for, one of which is having you as a wonderful and loyal customer all these years. I am very blessed to have been given the opportunities I've had since arriving in the U.S. 30 years ago, to be able to exercise my creativity at work, to live a peaceful life, and to be able to breathe in daily the freedoms that others yearn for."
It is so easy for those of us born to the privilege of being an American to forget what we have. As she points out, we breathe daily in freedom and we are so used to it that we forget how precious this freedom is.
With the beginning of a new year, 2006, it is a good time to make some resolutions. It is also the perfect time to take a hard look at what we have and what we have to offer. What we have to offer is what CRA and fair lending are all about. They are about making sure that doors are open for those who come to this country from war, political unrest, starvation, or lack of opportunities. They are about opening doors for people, including those born here, who have been shut out.
So the next time you have a meeting on fair lending or CRA, take a moment to remember the words of a naturalized citizen who was born in Vietnam. Think about all the opportunities you have had. Go into your meeting or training session resolved to share those opportunities and our freedoms with others.
Copyright © 2006 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 16, 1/06
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