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#2165649 - 02/23/18 05:35 PM New Compliance Officer
ComplianceGuru89, CRCM Offline
Member
Joined: Sep 2015
Posts: 85
So just recently I was appointed as Compliance Officer for a 5B bank. I've managed other departments/branches before so that aspect doesn't bother me, but I've only been in Compliance for 5 years so I'm excited with how far I've come in the short amount of time, but also really nervous... For the compliance veterans out there, are there any tips or recommendations you can make to a newbie?

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#2165657 - 02/23/18 06:15 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Retired DQ Offline
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Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
1. Read, read and read: regs, handbooks, newsletters, regulatory findings (to follow trends/hot topics).
2. Reach out to your peers.
3. Attend as many conferences that you can and network while there.
4. Subscribe to as many compliance services' free email notifications as you can.
5. Remember that you do not need to KNOW the answer, you need to know how to FIND the answer.

There is much more, but I am busy, this is a start. Good luck. smile
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#2165660 - 02/23/18 06:37 PM Re: New Compliance Officer ComplianceGuru89, CRCM
raitchjay Offline
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Joined: Oct 2009
Posts: 9,086
OK
When people want an answer to an important question, insist on giving it in writing (at least in an email). It's no fun to hear 6 months later "well, remember when you SAID _______________________" (with the blank being something that you didn't say, or something that you DID say about a TOTALLY different scenario).
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I'm fixin' to fix that.

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#2165663 - 02/23/18 06:43 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Retired DQ Offline
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Turnpike Exit 10
LOL... true...
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Get your facts first, then you can distort them as you please. - Mark Twain

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#2165664 - 02/23/18 06:46 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Skittles Online
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Skittles
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TN
AND you may have to ask 3-4 questions (or more) back to the coworker asking you the question to get down to the correct answer. Sometimes the devil is in the details.
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My Opinions Only

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#2165665 - 02/23/18 06:54 PM Re: New Compliance Officer raitchjay
Soccer Offline
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Joined: Jan 2010
Posts: 1,028
Utopia
Originally Posted By raitchjay
When people want an answer to an important question, insist on giving it in writing (at least in an email). It's no fun to hear 6 months later "well, remember when you SAID _______________________" (with the blank being something that you didn't say, or something that you DID say about a TOTALLY different scenario).


^^^This is fabulous advice.
Also, continue to develop strong relationships in the business lines so that they will feel comfortable asking the questions which could avoid problems down the road.


All the best to you!!
_________________________
Everything happens for a reason

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#2165668 - 02/23/18 07:10 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
The first thing I would do if taking over a new CO role would be to evaluate the current compliance audit function. I would want to ramp up testing so that I knew exactly what I was dealing with, so that I could focus my efforts accordingly.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2165669 - 02/23/18 07:11 PM Re: New Compliance Officer ComplianceGuru89, CRCM
ComplianceGuru89, CRCM Offline
Member
Joined: Sep 2015
Posts: 85
This is all great advice! I've experienced the multiple questions scenario first hand but I think the comment by Soccer would definitely help with that too. The previous Officer, really burnt a lot of bridges (hence the opening) so a lot of them are really apprehensive on discussing anything in detail if Compliance is around. So it'll take 10 questions just to get a simple answer, which is frustrating at times.

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#2165677 - 02/23/18 07:35 PM Re: New Compliance Officer Retired DQ
RR Sarah Offline
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RR Sarah
Joined: Mar 2004
Posts: 2,505
Up North
[quote=DeeQ
5. Remember that you do not need to KNOW the answer, you need to know how to FIND the answer.

[/quote]

This is best advice! You can't build trust if you guess at an answer and then have to recant it. I've been doing this a long time and still say for some things, "I'll research that and get back to you". There's no shame in that game.
_________________________
Sometimes you have to burn a few bridges to keep the crazies from following you.

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#2165678 - 02/23/18 07:36 PM Re: New Compliance Officer ComplianceGuru89, CRCM
RR Joker Offline
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The Swamp
Other than what everyone else has already said...I will simply offer you my condolences. smirk
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2165715 - 02/23/18 09:43 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Elwood P. Dowd Offline
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Joined: Aug 2001
Posts: 21,939
Next to Harvey
Dee Q's list reflects a lot of wisdom.

A footnote: There will be times when management overrules you. It's part of the job. You are not the bank's self-appointed savior: don't throw your career at the wall to see if it will stick. Leave a paper or electronic trail supporting your description of the problem and your recommendation of a solution and then go on to what's next.

More than once, I've heard a member of management say, "We were never informed of the problem. If we had been we would have certainly done something about it!" In reality, there had been heated discussions with management, they knew exactly what the problem was, they just didn't want to pay to have it fixed.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#2165756 - 02/26/18 01:51 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Monster Offline
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Joined: Sep 2015
Posts: 500
Fabulous advice above - but I too would like to agree that "5. Remember that you do not need to KNOW the answer, you need to know how to FIND the answer." & "AND you may have to ask 3-4 questions (or more) back to the coworker asking you the question to get down to the correct answer. Sometimes the devil is in the details." are two that I personally have learned the most from. A lot of times compliance and the departments don't get along due to compliance personnel thinking they know the answer, when instead they didn't take the time to find out for sure. Rules change often enough I pretty commonly pull the regulation with each question unless it is something I've researched 100 times.

I also agree that in writing responses help, and personally like to request the question in writing as well. Several times I've had a verbal question asked, and when I received it in writing, it came back completely different; this changes the response as well. (An email trail also makes me more likely to not overlook responding, and losing their confidence that they can come to ask any time.)

Lastly, work together. A lot of times people will ask "can we do this?" and it is something outright violating the regulation. Rather than "no", it can really help to provide the reasoning of what is being violated, and negotiate a new way for them to achieve their goal while remaining compliant.

I'm a relatively new CO myself, but so far this is what I've learned.

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#2166003 - 02/27/18 05:02 PM Re: New Compliance Officer ComplianceGuru89, CRCM
ComplianceGuru89, CRCM Offline
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Joined: Sep 2015
Posts: 85
Thanks everyone for the suggestions! I will keep all of them in mind! Much appreciated

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#2166218 - 02/28/18 08:18 PM Re: New Compliance Officer ComplianceGuru89, CRCM
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,844
Pulling people out of the ditc...
Originally Posted By ComplianceNewb89
So just recently I was appointed as Compliance Officer for a 5B bank. I've managed other departments/branches before so that aspect doesn't bother me, but I've only been in Compliance for 5 years so I'm excited with how far I've come in the short amount of time, but also really nervous... For the compliance veterans out there, are there any tips or recommendations you can make to a newbie?


why does senior management in your bank hate you so much that they would do this to you? umm, I mean, good luck and congratulations!
_________________________
Providing alternative truths since the invention of time

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#2166317 - 03/01/18 03:35 PM Re: New Compliance Officer ComplianceGuru89, CRCM
David Dickinson Offline
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David Dickinson
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Central City, NE
I started a series of CMS articles for our monthly newsletter last summer. Below is the 3rd installment in this series (it's still going on). I hope this helps!

Compliance Management – Part3: Compliance Officer Keys to Success
by David Dickinson

In the July newsletter, we continued our series on Compliance Management by discussing the role of the Board and Senior Management and began to discuss the role of the Compliance Officer. I hope you have been able to have healthy discussions with your Board and/or Senior Management to determine their risk appetite.

The Role of the Compliance Officer / Team
I’ve already mentioned this but please allow me to say it again, “the Compliance Officer doesn’t DO compliance”. Instead, compliance officers are responsible for the oversight and coordination of the bank’s day-to-day compliance activities. At the foundation of this, you (the Compliance Officer) must have a good working knowledge of existing regulations and also be well informed of the latest hot topics and changes. Your job is to then disseminate this information to everyone else on your Team. In other words, the Compliance Officer’s job is to MANAGE compliance. The role of everyone else in your organization (lenders, tellers, new accounts, processors, etc.) is to DO compliance. Thus, the Compliance Officer is the “Conduit of Information”.

Depending on your institution, some of you may also do some, or all, of these duties:
1. Auditing
2. Reporting
3. Correcting
4. Training

Keys to Success
Below you will find a list of suggestions and tips for Compliance Officers that I have developed over the years. I like to call them “Keys to Success”.

1. Have a “can do” attitude and be positive.
This includes learning how to say, “yes”. Too many times, the Compliance Officer is seen as the stop gate to things the bank wants to do. You shouldn’t have to ignore compliance requirements to say “yes”, but “no” shouldn’t be the first thing out of your mouth either. Find a way to say “yes” and still meet compliance requirements.

I often joke, “The answer is always ‘yes’. We might go to jail if we do that, but we can do it!” J A better response is, “Yes, we can do that; however, it would be best if we ____” (disclose this or that, make the mouse print bigger, add this disclaimer, etc.).

Here’s a catchy slogan to help you remember this:
Don’t be the Department of “No”. Be the Department of “Know”.

2. State the facts.
Too often Compliance Officers make up rules that don’t exist. The logic is to raise the bar to prove compliance happened or to make things consistent. For instance, getting everything signed to prove it was provided or waiting more than 3 days on a Right of Rescission. While these might be good procedures, they aren’t necessarily regulatory requirements.

Know the difference between the regulatory requirements and made-up procedures. If you try to pass off a procedure as a requirement and others find out, you lose credibility.

3. Defend rather than prosecute.
Be a Team Player. You should see yourself as an offensive lineman who defends the quarterback. You should never “tackle” your own Team Members. Another way of saying it is, “All boats rise and fall with the tide. Don’t sink your own ship.”

Along these lines, never embarrass anyone on your Team. Too often, Compliance Officers feel like it’s them against the world. When an auditor/examiner points out an issue with something you’ve addressed before, it’s very natural to turn to your personnel and say, “I told you so” or make other negative comments. If possible, take a bullet for the Team and say something like, “I must not have trained you sufficiently on that”. When other Team Members see you as being humble and a Team Player, they are more likely to come to you with issues in the future rather than hide them from you.

4. Trust people to do their jobs correctly.
Compliance Officers often create extra steps so others can’t get around the rules. For instance, having the Credit Score Disclosure signed in all cases to prove it was provided. If this procedure is created, eventually someone will fail to get the disclosure signed. Even if the disclosure was provided, it looks like a violation because the signature simply was not obtained.

Remember that Compliance Officers don’t “do” compliance. If extra steps are created, it creates bureaucracy and inefficiencies on top of the already burdensome requirements. This points back to a lack of credibility for the Compliance Officer.

5. Be realistic – Regulation vs. Real World
I often hear Compliance Officers use scare tactics like, “We’re all going to jail”, “We’ll be sued”, or “That will get us a penalty”. Most Team Members don’t buy these scare tactics even if it is possible and again, the Compliance Officer loses credibility. The sky is not falling!

6. Pick your battles according to risk.
Ask yourself, “Is this a hill worth dying on?” Not everything is a big deal.

7. Partner within the bank on projects (i.e., other business lines).
Like #3 above, see yourself as a defense attorney, not a prosecutor. Say, “I’m here to help. How can I make your life easier?”

Spend time with your personnel (backroom/tellers/loan processors). Find out how they do things and see if you can make their lives easier. Try to see things from their side of the desk to fully understand how regulations and procedures affect them. Then try to help them develop procedures to carry out the regulatory requirements in the most efficient way possible.

8. Network with other compliance professionals.
In most cases, compliance is NOT competitive! Share ideas, policies and procedures. Plus, having a network of peers is great when you simply need a shoulder to cry on.

9. Use examiners as a resource.
a. Call and/or meet with them regularly. Establish and maintain a quality working relationship with them.
b. Ask for their advice. What are they seeing? How do others do this? New interpretations? But also understand, examiners are not your auditors and they can be wrong. Don’t necessarily believe everything they say or suggest. You still have to do your homework but examiners do have a wealth of knowledge when it comes to seeing a lot of different ways of doing things.

10. Know for yourself.
Research regulatory requirements and know what you believe they mean. Don’t ever say “So and so said ....”. If you hear something you don’t understand or have understood a different way, ask for the reference/source, so you can look it up. Don’t be like a sailboat going every which way the wind blows. If you do, sooner or later, you’ll come across interpretations that are mutually exclusive.

11. Admit when you’re wrong.
You’re probably “wired” as a perfectionist with an eye for detail, but trust me, you can’t be in compliance and always be right. When you don’t know something, admit it. When you’ve misunderstood something, advised someone incorrectly or just made an error, confess to it and move on! Often, everyone else already knows, so it’s simply an act of humility. No one expects you to know everything. No one expects to you to be perfect. But when you act as if you are never wrong, it will become someone’s mission to prove otherwise.


Meeting The Challenge
Of course, there’s more than these eleven suggestions to being a good Compliance Officer, but if you can master these, you’ll be seen as a humble and smart Team player.

We’ve talked a lot about your role and approach as a Compliance Officer. Next time, we’ll begin to get tactical by discussing risk assessments. Until then, try working on the things mentioned in this and last month’s articles. Also, be sure to have healthy discussions with your Board and Senior Management about their risk appetite, expectations and your role. It will be worth it!
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2166319 - 03/01/18 03:42 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Soccer Offline
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Joined: Jan 2010
Posts: 1,028
Utopia
^^^
Great advice and a plug for David and his team, subscribe to their newsletter, it is worth every penny!
_________________________
Everything happens for a reason

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#2166452 - 03/01/18 10:47 PM Re: New Compliance Officer ComplianceGuru89, CRCM
David Dickinson Offline
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Central City, NE
That's very kind of you to say Soccer! Thank you.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2166546 - 03/02/18 07:07 PM Re: New Compliance Officer ComplianceGuru89, CRCM
ComplianceGuru89, CRCM Offline
Member
Joined: Sep 2015
Posts: 85
That was a great article Dave, thank you for sharing! And I will definitely look into the other articles/subscription!

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#2166581 - 03/02/18 09:07 PM Re: New Compliance Officer ComplianceGuru89, CRCM
David Dickinson Offline
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David Dickinson
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Posts: 18,762
Central City, NE
My pleasure! Good luck to you ComplianceNewb. If you need help, give us a call.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2167445 - 03/09/18 05:43 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Tracey, CRCM Offline
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Joined: Jul 2015
Posts: 542
Gorham, ME
I will second Soccer's comments- David & his team have been invaluable to me as a resource.
_________________________
Tracey

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#2218837 - 07/31/19 04:40 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Eagle06 Offline
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Joined: Jan 2018
Posts: 22
I am new here, but I have to agree- David's articles are a must read!

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#2218866 - 07/31/19 07:41 PM Re: New Compliance Officer ComplianceGuru89, CRCM
Retired DQ Offline
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One other thing of note, make sure that your respective departments understand that you are there to help them and guide them, and you should be looked upon as a resource for them, I always got their 'buy in'....

And as I always said, better that I find the issue than an examiner, then we can correct and move forward.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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