The two questions below are not about your sources for compliance research. The two questions are about your sources for getting answers to questions your research did not answer. Also, the questions are only for those of you who have been compliance officers since 1995, 1996 or 1997. Here are the questions:

Question 1: In 1995, 1996, or 1997, what resources did you use to get answers to questions you could not answer after diligent research? (Please state the year you began working in compliance.)

Question 2: Since 1995, 1996 or 1997, how have the resources changed that you use to get answers to questions you could not answer through your own research?

I assume that in 1995 many of you did not use or have online resources for tough compliance questions. I assume that at that time, many of you called regulators, Kirchman, bankers associations, etc. I assume that since 1995, your reliance on regulators, Kirchman, state bankers associations, etc. has decreased as other resources (particularly online resources such as Bankers Online) has increased. Maybe my assumptions are incorrect.

Your answers will help me to document the changes in banking compliance in the last 8 years. I need this information to show management one element of the changing nature of compliance. If you want to mention other changes to the nature of compliance, please feel free to mention them. Thanks.

1. You are right that I didn't use an online source in 1995. I frequently called and wrote letters to the Federal Regulators.

2. I now email the regulators occasionally, but it has become quite rare because of the exchange of information BOL!

My main resources were compliance newsletters, the Federal Register and state banking groups. Today I rely on the Fed Guide (CD version), regulator's websites and Bankers Online.

So, your calls, emails, etc. to your state banking groups has dropped precipitously?

In the 90's, I had several bookcases full of reference guides, including regulatory subscriptions. If that didn't yield results, I used inner-company resources (worked for a large holding company at that time). Attorneys were an option for questions I couldn't answer through research, as well as our regulators and state banking associations, or the ABA.

Now, I have half a bookshelf filled with some bank-specific and state-specific resources. Most all my research is done either on-line or by electronic regulation subscriptions. I rarely make use of the state banking association, except for state-specific issues. Email is great, but BOL is awesome! That most always answers the tough questions.

I've been a full time compliance professional since 1988. Prior to online resources, I primarily relied upon:

• Calls to field examiners,
  
• Calls to FRB staff in Washington DC. (It's been years since I've called the Board of Governors staff to ask a question.),
  
• Federal Register (paper!)
  
• Regulatory agency mailing lists,
  
• Other compliance professionals,
  
• Phone calls to ABA staff,
  
• Paper regulatory services,
  
• Dial-up regulatory services (BBS, not Web),
  
• Phone calls to speakers heard at conferences.
  

Now, I can usually find almost anthing I need online. The Internet has really changed everything. Not only has it made it easier to access information and network with peers, it has also changed the nature of my job. I am more efficient and I feel much better informed about what's going on.

I still do, however, subscribe to a paper version of the Federal Reserve Regulatory Service. For me, I find that most of the time it's just easier to scan a printed page than a computer screen.

Hope this helps.

-- Tony

Most of my information came from newsletters, Kirchman and other training/consulting firms that allow phone calls IF you attended one of their seminars. Frankly, maybe I just didn't know any better, but it seems like I didn't have near as many questions back then. It may be due to the fact that our institution has grown substaintially during that period. Dealing with more folks and more issues (HMDA and Large Bank CRA.) I've been doing this since 1988. At that time I had a sense of humor and a personality.

In reply to:

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Question 1: In 1995, 1996, or 1997, what resources did you use to get answers to questions you could not answer after diligent research? (Please state the year you began working in compliance.)

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Calls to the ABA, regulators, Kirchman (printed materials from each as well as vendors and industry publications and the FRRS weer used for research, call it diligent or ultra-diligent, see my comment below) or $counsel$. I started compliance in about 87, heavily for both my banks in 90.

In reply to:

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Question 2: Since 1995, 1996 or 1997, how have the resources changed that you use to get answers to questions you could not answer through your own research?

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I started dialing Richard Insley's bulletin board in about 94, I think. At that same time networked with others in compliance on AOL. You'd be surprised how many "environmental compliance" folks are out there. Most just say compliance. That was how I "met" Dave Mulkerin, as an example, who uses this board.

That has evolved into things like BOL, Webcast conferences, regulations on CD and the Internet and Web in general. Now we have resources which include our peers real world experiences (one form of Net-working, get it!) and their regulatory knowledge. E-research, using keywords makes things 99% easier. As examples, reading the Federal Register, industry publications from vendors, regulators, etc. has improved research time and results exponentially because we can focus on the meat we are after! Web search engines fall into this same category.

When I went to compliance school I took section after section of my FRRS regs. Now it is in e-form on my laptop and my PDA. Articles and memos are always at hand, organized and searchable. Information is power.

Pre-1994 I walked six miles to work in the snow, uphill both ways. Post 1994, I had a 10-speed and then a car, then a limo as the Web developed. 5, 10 years from now. Watch out.

#1)
Officially starting in 1996- my resources were the big orange book - RCS, ABA, CBA, ICBA periodicals, FDIC FIL's and Press Releases, Federal Registers, misc. regulatory updates. (all hard copies) In addition there were phone calls to outsourced auditors, and regulators or other Compliance Officers.

#2
With the change of command comes drastic cutbacks in periodicals - cut,cut,cut... I was down to one resource ABA Compliance Magazine and the introduction to the Internet. The internet has been a life-saver. FDIC FIL's are easily accessable, and sooner. Other Resources are now availabe on line that were impossible to reach before. And most important of all Bankers OnLine was created .

With the Growth of the Bank and the reduction of staff Internet resources is the life line to success. When regulators arrive, and research is needed to clear a discrepancy I can usually remedy the situation the same day or prior to their departure. Back in the "ol days" - this wouldn't have been as easy. Self Confidence has also improved.

This is a fun little walk down memory lane I've been working in compliance since around 1985. We had a former OCC examiner on staff who helped me with the tough questions at that time. After that, it was through dial-up access to the Federal Register, calling the State Banking Department or Association, kirchman, Sheshunoff, etc...

Now, everything is on-line. BOL is the best resource, however I still maintain a good relationship with our regulators and use them frequently when I have questions. The only time I use the STate is when it is a state -related question.

I was one of the resources , at least for national bankers in Oklahoma back in '95-97. Went full blown compliance specialist in 1998 with the OCC, and was often in the SW District Office answering phone calls from bankers all over the district as the "Compliance Rotator". Even we had to call higher ups in Wash. D.C. when we weren't sure of an answer right off the bat.

I was also a resource for several years in the mid-to-late nineties until early in the new century at a state bankers association.

When calls dropped off during that time, I had fun explaining to my supervisors that the drop off in calls was not because of me, but because of all the new available resources. By the end of my time there, I got almost no federal questions. If I ever have a job again where part of my evaluation is based on the number of compliance question calls I get, I am going to call the compliance officers and ask them what they are currently dealing with and then log those as compliance calls. That would keep management happy and the compliance officers would be amazed at this wonderful new service. (See, compliance officers are not the only ones who are misunderstood by management.)

I would love to hear from more of you who were resources back in '95, '96, '97, etc... and the changes you have seen until today. MaryBeth was a resource during that time. Who else out there was a resource during that time. What are your experiences? Did you notice a drop off or change in the type of calls?

I was drafted into compliance in 1992. I really didn't know anything about compliance at all. I subscribed to every periodical I could find. Leaned heavily on Sheshunoff books. When I went to the ABA Compliance School they told about the Fed number for compliance questions -- that was a godsend. I joined a peer association and did a lot of networking. I didn't get a lot of help from my regulator then (OCC). Back then, they weren't too helpful. Now, I still get a lot of periodicals, and I still use Sheshunoff, but I can't remember the last time I called the Fed. I still belong to the compliance group and use them a lot for brainstorming. The OCC is much better about questions. I use them when I am really stuck now, whereas before, I would have called the Fed. In the short time I have been using BOL, I find I do use this resourse more and more. But for the most part, I rely on my friends at other banks. Whenever I meet someone new to compliance, I cannot stress enough the importance of getting to know other compliance officers at other banks, over the years this has been my most important resourse. (Thanks to everyone out there I've met over the years, Thank you,thank you, thank you!)

I was a compliance Newbie in 1997, and was still trying to learn the difference between a law and a regulation! Like everyone else, I used Kirchman, the State Banking Association, peer groups and the ABA. My boss, who has now retired, had been in compliance for years, and had a lot of contacts in the compliance world (like Richard Insley) whom she relied upon for help. We also used Lucy Griffin and Compliance Action. I can also remember sending desperate emials to Alan Dombrow!
Leslie

What about now? What has changed?

Sorry - I thought you were looking for names of people we used as resources back in the olden days!!
NOW, I can't say much has changed regarding the people I use. I still use Lucy and Compliance Action, ABA, Richard, peers,and anyone else I can find! Of course, now that I am much more internet savvy, and have taken several college courses in legal research on the internet, I find I do much more research on my own before I give up and post the question on BOL! I use Lexis and Google as well as the individual legal and regulatory websites. I still use Kirchman on occasion, but I use BOB online,and seldom call them. I could submit my questions to ABA via e-mail, but I prefer to call Bill Hood at ABA on a regular basis because I like him and enjoy talking to him!
Leslie

Thanks for all the input. I hope more of you relate your experiences.

1-Back in the early and mid 90's after exhausting my own resources I found compliance help through ABA's and Kirchman's hotlines. But my best source of additional information was from a local (Birmingham, AL) roundtable of other compliance officers.
2-Best resources now -- the internet and BOL.

My, how things have changed!

Around that time (say '98), I used manuals from banking and legal educational seminars attended, books, books, and books in my office, a West CD-ROM, the fed's websites, attorney contacts, and Kirchman's BOB and free hotline.

Now, I use Lexis, BOL, fed and state websites, multiple attorney contacts, the many files I have developed (both paper and computer), state banking department website, and very few books. Sometimes, I even take a wild chance by typing in key words in a Google search--amazing what it comes up with.

[I keep separate Word files--title by topic--of answers to questions that I think may come up again.]

I started 'doing compliance' part time in 1988 and went full time in 1992. Banking schools, seminars, FDIC, in-house former FDIC examiner (my mentor) and lots of periodicals were the resources of the day.

I started using online pretty early, as Andy mentioned, and now I only have 2 periodicals, a regs-on-CD subscription and the Internet (BOL especially!) as my main resources.

I agree this question is a trip down memory lane. I have been a full-time Compliance Officer since 1985 (don't forget to add a few of those other CRA/BSA/OFAC/Privacy/Security hats nobody else seems to want...ha,ha). Most of the resources I used were similar to what everyone has been mentioning. But looking back on what proved most helpful in researching/understanding an issue was writing comment letters. It seemed like in the late 80's to early 90's there was alot of new legislation in response to the S & L disaster/commercial real estate market, etc. and obviously the FED was requesting comment on many subjects. I would study what was being proposed and then try to figure out (with the help of fellow employees) how it might impact our operation. When the final reg. would be published, I would carefully review the supplementary information (to the final reg.) in the beginning of the Federal Register (kind of like the preamble) to figure why the FED decided to go a certain way with an issue. Also, it let me know whether I was understanding the proposal correctly and most importantly what did other commenters write? Although it is always a "tough read" (never to be done after lunch) I am always amazed at the depth of the analysis to the issues by some of the commenters. To this day, if I have a question on Reg. DD (I don't go to BOL first on this one) I turn to the Federal Register from September 21, 1992 and search the 39 page "Supplemetary Information" to the final reg. to find my answer. It is normally there.
In these 18 years in the compliance field, my only brush with compliance fame came in 1995 with the proposed commentary to the lunacy known as HMDA. I wrote a comment letter with several real-life examples that were impossible to make the correct HMDA determination/coding, etc. without some additional clarification that the new commentary could provide. Sure enough, there in the Supplementary Information to the final version was a reference to "One commenter requested guidance on such and such....so in the final version we added such and such". It was compliance heaven on earth.