Can anyone relate to my situation? I'm the compliance officer at a small bank (about $260 million with 4 branches). I am constantly providing training to staff about regulatory changes, but it seems to be okay for certain staff members to disregard regulations and someone else is expected to correct issues after the fact, but before regulators come in. Am I wrong in thinking everyone should be responsible for knowing the regulations that apply to their jobs? Some members of management feel it is a lenders job to make loans and they can't be responsible for ensuring all of the documents are filled out accurately. What?! Isn't compliance everyones responsiblity? I'm very frustrated with the situation and wonder if it's common. It seems no matter how much training I give some people are just going to continue doing whatever they have been doing.

Is there room for more than one on the soapbox?

Step aside on that soapbox....

I think we all get frustrated from time-to-time (or was that all the time?)with the situation in which you find yourself. I've always held that we are all responsible for ALL aspects of our jobs. That includes not only doing it, but doing it right and doing it according to all policies and procedures, including those promulgated by the regulators. My job is to help a loan officer (or any other employee) understand the regulations for which they are responsible, to help develop tools that make that understanding and 'conformance' easier, and to monitor compliance with those regulations. However, in the end I can't do it for them.

There are a lot of smaller institutions that seem to work this way. One of my problems here is I train, we get examined and do very well <we're small and they don't dig>. I see issues but I really can't fuss because the examiners don't see them. Kind of a 'Catch 22'.

All employees are suppose to be evaluated on compliance in their performance reviews. I am in the same situation as you are. I train train and train until I'm blue in the face. I find the same errors and report to management. I document everything I do on training so both examiners, Board, and management are aware of training and to stop the errors and to also protect myself. In the end, the employee has to take some responsbility.

Which they won't do until their feet are held to the fire and they are made to do it by the only ones who can make them...the one who signs their paycheck. Unless you have the full backing of management behind you (picture a big muscled guy standing there bouncing a base ball bat in the palm of his hand and looking menacingly at the offender) you're going to continue spinning your wheels through retraining. Management usually steps up right after the examiner nails your FI on the issue you know exists right now.

Hang in there and don't take it personally. We're all in little boats just like your's. Some of us are a tad further upstream just past the Examiner rapids.

That reminds me of the Priceline commercial with the huge guy talking about the deals.

Sorry - now back to the issue at hand.

This is funny. The girl that works as my assistant caught me first thing this morning and asked me if I posted something on BOL yesterday. We laughed because I could have very well posted the original post myself! Everything said in this thread is so true! When examiners find the problem, then it becomes real.

This happens ALL THE TIME! Unfortunately at our last exam it was all blamed on me as compliance officer, even though I had reported the same offenses to management for several years! It seems like everything I do is absolutely meaningless. I'm tired and frustrated with retraining on the same [censored] year after year and no one doing anything differently.

Ditto on the frustration. If the examiners are keen enough to point out to management that compliance is everone's job that can really help. Presently, at my bank we are having some safety and soundness issues. Therefore compliance exams have been light because there are "bigger fish to fry".

I find it difficult in some respects because, like others i'm sure, i was hired and immediately made the compliance officer. So while trying to learn banking in general and compliance specifically was difficult enough...i very quickly found myself being asked questions on a broad array of topics, including operations for example. It is difficult....i actually feel proud of myself for learning what i feel like is a lot about compliance in the short time i've had in this career, yet, i still feel woefully ignorant of so many aspects of banking. I don't know if it's like this everywhere (but i have a good idea it is), but it feels like i'm back in elementary school sometimes playing musical chairs.....everybody's basic instinct to pass the buck and make sure blame doesn't land on them. As a compliance officer, although it hasn't really happened yet, i feel like i'm set up at some time in the future to be the fall guy...if that makes sense.

Sadly it does make sense. I don't know about other areas of the country, but for as long as I've been in banking in PA the motto pretty much has been "CYA" cover your a$$.

It's often a huge waste of time teaching regulations to bank employees. Instead, concentrate on digesting the regs and developing procedures and systems that will improve your chances of complying. Be sure the procedures and system changes make sense to the operations staff that supports the affected business unit(s). Then, teach the procedures.

Sometimes, very simple adjustments can make a big difference. A couple of examples:

- My CTR review staff was experiencing great difficulty distinguishing between large cash transactions (reportable) and "look alike" large cash transactions (not reportable.) Look-alikes resulted with tellers used a cash ticket as the offsetting entry in a two step transaction such as a large check presented for split deposit into two accounts. The usual practice had been to debit "cash items in process" and credit "cash" for an equal amount. Then the teller would debit "cash" for the two deposit amounts and credit the accounts involved. There was never any cash on the counter, but a reviewer could not tell that from the record created with the cash tickets. Our solution was to establish two new tran codes which we nicknamed "cash look-alike in" and "cash look-alike out." The final process change was to reprint our cash tickets as two-sided documents: real cash in/out on one side and look-alikes on the other. Tellers liked the new process (because the CTR reviewers stopped hassling them), reviewers loved it (because it eliminated their biggest waste of time), branch management liked it (because it was cheap, simple, and effective), and I loved it!

- Forms with check boxes were a constant source of errors and (more often) omissions. Wherever possible, we reworded the forms with default language and the ability to override. For example, Reg. Z requires a disclosure when loans contain a demand feature. Since very few loans actually had a demand feature, we reworded the forms to say "This loan does not have a demand feature unless this box is checked. [ ]" With the new wording, the form always disclosed something, and since omissions had always been a bigger problem than errors, we improved our odds of getting it right.

Richard,

First of all, thanks for the great tips!

I agree on the training; most of it seems to be just to ensure that the staff get the training that the regulators require. getting anyone here to train is worse than pulling teeth.

More importantly though, as you've stated, I try to embed the controls into the process, either manually or electronically. Once the (compliance) controls are part and parcel of the process itself, it helps get rid of the 'us vs. them' mentality when it comes to doing things for compliance purposes.

Document; Document, document, everything. Policies; procedures and review and/or compliance reports. You may even want to keep a journal (private) at home.

It is also great therapy to detach your frustration by writing it down and keeping it. If you get canned from your job for not doing it correctly, find a very good lawyer and give them the documents. U may be able to retire like me!

Just popped in to see how things are going.

You may want to sit back and take a hard look at how you are approaching your training. I don't waste my time teaching employees the nitty-gritty details about every regulation. It bores them. I provide them the basic information they NEED to know and then I focus on what they need to do as part of their job. Make their lives easy by building compliance into the workflow. Have good procedures, flowcharts, tools etc. that they can use. They will be complying and won't even know it in most cases.

I take great pride in making myself "user-friendly" so that employees will call me when they think they might have a compliance problem. I include them when I develop procedures or make changes to forms. They appreciate this and it makes a huge difference in how you are perceived. The reality is that when you make an effort to care about what they have to do on a daily basis, they are more receptive to doing things right to make YOUR job easier.

Dolly's bang on with her statements. Employees don't need to know the Regs or where to look for support. You do. I train mine with 'The Reg has changed. This is how it affects you.' I spend a good part of my time answering specific instance questions which is just how I want it to be. I want to make the call on oddballs rather than have them feel they can/should wing it.

Having all the procedures/charts, etc., in place is also evidence of addressing issues in case you ever need it, as is keeping documentation to cya.

That sounds good in theory, but the staff at my bank expect me to tell them how to run their software programs and how they work. I don't even have access to the programs!

Senior management feels every rule can be broken and since they're senior management they can do what they want. It's very frustrating!

Amen, Fallgirl. Amen.

At our last exam, for example, the examiner told me I needed to teach the lenders how to pull flood determinations. My answer: They have written procedures - with PICTURES! - that show them how to do it, but senior management has never had any consequences for simply not doing your job, so many of the lenders just don't pull the floods, or they are pulling them only after being written up. Unfortunately, since the exam none of this has really changed, and I fully expect to be the scapegoat the next time regulators show up.
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sadly, our BSA/Compliance training is like many peoples, the person doing it knows the changes, regulations, and laws, but doesn't know how to get it across to anyone. It is frustrating for her, double so for the rest of us...

Did you really tell the examiners that senior management isn't backing up the compliance section and nothing happened? Thank cod my management isn't like that!

As far as getting everyting across to everyone, Happy, I've come to believe that the compliance person needs to know the changes, regs and laws but no one else really does. Once I stopped trying to explain why to everyone and just said 'this is the way it is now' training took hold.

With regard to software, I don't know how to use them either. I announced just that to those people who use it too. When the updates came out, I reviewed the new GFEs, etc for compliance but never tried to learn how to do it. That's not my job.

My bottom line is learning that a job in compliance is 75% knowledge that changes daily and 25% chutzpah to carry through, make decisions and know when to say no. Remember to document and cya until such time as management acknowledges your abilities and backs you as necessary. Hopefully it will happen sooner rather than later.

IMHO - Life is way to short to get "frustrated" at work. Work is work - it is not easy.

Work: exert oneself by doing mental or physical work for a purpose or out of necessity.

If you don't like where you are - move. Sitting, complaining and worrying about it doesn't accomplish a thing, except shorten your life.

Work to live, don't live to work.

@rlcarey - it's not that easy. Believe me, I've tried.

I agree with Randy. I have been put in positions where I had to train myself to give my 110% and walk away at the end of the day knowing I had done my part or I think it would have driven me crazy. I was able (eventually) to train myself to leave it all at the office. I don't talk about work at home and I don't allow it to "own" me. It got me through some tough times with at least most of my mental faculties still intact, and never having succumbed to medicinal remedies.

I am grateful that God has helped me learn how to refocus. I am NOT saying it was easy. But it can be done.

Agreed. I had to get to the point that I CAN'T make them do it right or learn. It took me years and years to understand that.

I just have to be sure that I gave them all the training and tools necessary. I'm no longer responsible for them and I now understand that. I'm only responsible to my conscience and that I did 110% of my job and that management has no doubts. I'm so lucky in the management of this organization and in my boss. She knows and appreciates my commitment to this organization and to her.

Sorry if that sounds preachy, but it wasn't easy getting to this stage.