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#1592241 - 08/16/11 02:26 AM I could scream at Complaince Officer
Anonymous
Unregistered

We are going through annual training and one of my staff members found a glaring discripancy concerning a complaince issue in a handout of the banks's policy and what the Regulation says.Its not a major issue but. The Bank is not in complaince at any rate. I had her write up a plainly worded email memo, highlighting the relavent section in the reg and a link to reg on the FDIC website and asking our Compliance Officer to explain the banks's policy. What we got what was a one sentence reply that regurgitated the handout section. No explination of why we were wrong, no effort to point out reg that backs her assertion up. It obvious to me that she took no time to actually read the email in its entirity.I'm not going to have my staff member beat her head against the wall for a Phyrric Victory. A coworker was recently reprimanded for calling out a mistake of someone at HQ. Its sad but our Corporate Office is staffed by ossified fossils who have obtained positions on friendships with President and his top officers, 75% of whom have been around since the creation of the Bank. I'm going to explain to my staff the Bank's Official position and my advice to them to let the regulation govern their actions instead. And also to commend staffmember for her diligence in regulatory complaince.

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#1592242 - 08/16/11 02:29 AM Re: I could scream at Complaince Officer Anonymous
Anonymous
Unregistered

Sorry for misspellings and poor grammer. Submitted from phone.

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#1592246 - 08/16/11 02:46 AM Re: I could scream at Complaince Officer Anonymous
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Is corporate being stricter? They are within their rights to be stricter than the reg. Hard to tell from the post. Also, when a reg gives options, corporate has to pick one way to make it work and disregard options.

If they are out of compliance that is another discussion, but again hard to tell from this and it needs to be worked out internally anyway!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#1592248 - 08/16/11 03:17 AM Re: I could scream at Complaince Officer Kathleen O. Blanchard
Anonymous
Unregistered

No- its a consumer reg where the Bank has to comply and the Bank is acting in a manner that overruns the explicit boundaries set by law. Its nothing big (as in- keep me up at night, the bank is getting ready to take a fall if audited). Clearly- my staff member is right- the bank policy is absolutely against the relavent regulation. Just more frustrated with this incident and how Corporate treats branch staff. This staffmember didn't have to take time to read handout and then analyze it against the regulation, She could have accepted the erronous handout as correct and Corporate would have been happier. We are dumb- they are smart, don't ever show us up or we'll make you look bad since we have more access to Officers etc
etc.

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#1592251 - 08/16/11 08:32 AM Re: I could scream at Complaince Officer Anonymous
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
I'd think long & hard before refusing to comply with company policy. In most businesses, that will lead to disciplinary action and a blemish on your personnel record. If the issue is "nothing big", I'd sit back and let the originators of the policy take the fall when your regulator drops in. You're on record challenging the policy, so you've done as much as possible. If your bank has settled into a good-old-boy management style and there are other examples of poor decisions, you might want to look for a job within a better-run organization.
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#1592264 - 08/16/11 12:33 PM Re: I could scream at Complaince Officer Richard Insley
Bob The Banker Offline
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Bob The Banker
Joined: May 2010
Posts: 958
What is this specific regulation and what is the Bank's policy? Maybe there is an explanation... sometimes people that are not used to reading regulations mis-interpret or do not read the full regulation, including definitions, and may erroneously arrive at an incorrect answer... or your Compliance personel may just be wrong...

What is the actual issue?

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#1592350 - 08/16/11 03:21 PM Re: I could scream at Complaince Officer Bob The Banker
SouthoftheBorder Offline
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Joined: Feb 2002
Posts: 335
The South
I had a similar problem at a bank years ago - management may know the correct compliance stance but they choose to take the risk associated with not complying - It is their decision and I would not rock the boat if I were you.

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#1592382 - 08/16/11 03:55 PM Re: I could scream at Complaince Officer SouthoftheBorder
Comply 101 Offline
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Comply 101
Joined: Jul 2001
Posts: 708
Anon, as a former branch manager, I feel your pain. But as others have pointed out, your us against them mentality won't serve you well at your present location. Better to let this one slide. I had troubles similar to you except as a compliance officer. Many times, we have to deal with bank executives that don't "believe" the reg really means what it says. I used to work at a bank similar to you for 18 years.

Don't wait as long as I did, get out if you can. You just can't win/succeed at some banks.
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#1592456 - 08/16/11 05:25 PM Re: I could scream at Complaince Officer Comply 101
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Originally Posted By: Comply 101
Don't wait as long as I did, get out if you can. You just can't win/succeed at some banks.


Yup. Whether or not the reg being violated is large or small, a violation is a violation. This usually indicates that Management doesn't take compliance seriously. I was at one FI that took the position that compliance was a burden. I got out of there ASAP. I suggest you do the same.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1592482 - 08/16/11 05:58 PM Re: I could scream at Complaince Officer ACBbank
Anonymous
Unregistered

Oh, the woes of the compliance world.

I agree with the other thoughts here. You don't know how or why the decision was made- or even if it is the right one. Policy is policy however, and you should follow it.

On the same token, if you think something is really out of line,communicate it to your internal auditor and see what they think.

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#1594011 - 08/18/11 09:57 PM Re: I could scream at Complaince Officer Anonymous
Sing A Little Offline
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Sing A Little
Joined: Jul 2006
Posts: 3,889
CA
I would follow the policy set forth by the bank. They are making a business decision (not necessarily a good one) to ignore a regulation. Keep your documentation of the situation and let things play out.

I will agree with what others have stated, it might be time for you to think about whether this is the bank you'd like to continue your career with.
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He who sings scares away his woes. ~Cervantes

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#1594022 - 08/18/11 10:29 PM Re: I could scream at Complaince Officer Sing A Little
DD Regs Offline
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DD Regs
Joined: Nov 2008
Posts: 4,132
Somewhere in the middle
Originally Posted By: Sing A Little
I would follow the policy set forth by the bank. They are making a business decision (not necessarily a good one) to ignore a regulation. Keep your documentation of the situation and let things play out.

I will agree with what others have stated, it might be time for you to think about whether this is the bank you'd like to continue your career with.


Well said, my thoughts exactly.
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I'm only responsible for what I say, not for what you understand.

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#1594398 - 08/19/11 07:31 PM Re: I could scream at Complaince Officer DD Regs
NU Rhules Offline
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NU Rhules
Joined: Mar 2011
Posts: 461
SE, Nebraska
I like the internal auditor suggestion. You may be dealing with an "office bully" who can't handle being corrected. And with the addition of being backed up by higher ups, that makes it tough! As a former USAF officer, I rail against willful disregard of regulations as a matter of contempt. If this is true as you say, I'd also be looking elseware for work. Additionally I love your command of English evidenced by the use of Phyrric and Ossified. Love it! Consider teaching!

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