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#307728 - 01/24/05 09:29 PM Compliance Goals
CSB98 Offline
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Joined: Dec 2003
Posts: 1,341
Wisconsin
My supervisor wants me to come up with some goals for the upcoming year that will be a factor in my evaluation and raise for next year. In past years we have had four goals and so far he has only been able to think of two -- certain % of audited files in compliance and certain # of in-house compliance training sessions. I have been at a loss as to what else can be tracked for goals. Anyone have any suggestions?

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General Discussion
#307729 - 01/24/05 09:36 PM Re: Compliance Goals
Bullseye Offline
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My goals include such things as analyzing HMDA/CRA data, providing regular reports to my committee, reporting to the BOD regularly, monitoring things such as marketing materials and our website for compliance and reporting errors to committee. I suppose in a nutshell, they say "look for problems, summarize & report all information to the higher-ups".

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#307730 - 01/24/05 10:07 PM Re: Compliance Goals
HRH Dawnie Offline
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Anchorage Alaska
We all (our compliance officers) have referral goals for new business. In addition, I set specific goals for data integrity, investment levels and CD Lending goals. Factoring in exam outcome goals is valuable as well.
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#307731 - 01/24/05 10:42 PM Re: Compliance Goals
Andy_Z Online
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Quote:

certain % of audited files in compliance




I would not put that in my goals if I am reading it correctly. If you don't find errors, you meet your goals? Say it ain't so. This is beyond your control if you are an auditor as well. If this relates to you training staff and the results they see from another party, that would be different.

Look for things like error free LAR submissions. Meeting your audit schedule. Improving the staffs knowledge as evidenced by pre- and post-testing. These are measurable. Other items are somewhat measurable but are more like checklist items, presented to the board, completed training...etc. So much of what you do is subjective in nature, this can be difficult.
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#307732 - 01/24/05 11:26 PM Re: Compliance Goals
someone else Offline
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someone else
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back to my roots
My goals for the year are:

1. Creating an online training/learning program for Mortgage Lending staff.
2. Creating a comprehensive internal compliance policy and procedure manual for every desk in the department as well as posted on the intranet.
3. Creating a compliance calendar that will allow me to tackle each and every compliance issue instead of the haphazard way it is being addressed now.
4. Bringing our originating system into compliance with the regulations (even if it kills me!!).
5. Auditing my LAR quarterly (or more frequently if possible)
6. Finally going to compliance school!

Sound like a fun year?
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#307733 - 01/24/05 11:36 PM Re: Compliance Goals
HRH Dawnie Offline
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Anchorage Alaska
Just curious....I keep hearing "auditing the LR/LAR" but no "submitted with less than 1% error, etc." Just looking won't benefit the bank...is someone goaling the submission?
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#307734 - 01/24/05 11:59 PM Re: Compliance Goals
someone else Offline
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someone else
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back to my roots
I am shooting for a "less than 50% error" rate...oh wait...guess I shouldn't publicize that! Hahaha!
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#307735 - 01/25/05 12:00 AM Re: Compliance Goals
Anonymous
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My primary goal for 2005 is to develop and implement a formal enterprise compliance management program. So far we've been getting by with a somewhat informal program. Even though we got a "1" compliance rating last year, the time has come to get more formal.

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#307736 - 01/25/05 02:56 PM Re: Compliance Goals
redsfan Offline
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Quote:

Just curious....I keep hearing "auditing the LR/LAR" but no "submitted with less than 1% error, etc." Just looking won't benefit the bank...is someone goaling the submission?




You bet - error rates for HMDA and CRA submissions are part of my goals. I have passed those goals down to our CRA/HMDA manager.
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#307737 - 01/25/05 04:16 PM Re: Compliance Goals
CSB98 Offline
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Joined: Dec 2003
Posts: 1,341
Wisconsin
Thanks everyone for all your suggestions. I like the idea of having minimal or no errors on the HMDA LAR since we've had issues with that before in recent exams.

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#307738 - 01/25/05 05:27 PM Re: Compliance Goals
Anonymous
Unregistered

I prepare an annual calendar and after year end I look back to see just how much(%) of what I scheduled to accomplish I actually did accomplish. In certain years mitigating factors out of the ordinary prohibited me from getting close, but I knew that. This is a self testing tool. No one in senior management has ever questioned me about what I do. I tend to be a workaholic.

If you push yourself others will appreciate it.

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#307739 - 01/26/05 03:11 PM Re: Compliance Goals
Anonymous
Unregistered

I know we will have a full exam compliance exam so one of my goals is to effectively prepare for and manage the compliance exam.

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#307740 - 01/26/05 03:48 PM Re: Compliance Goals
KAT Offline
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Joined: Aug 2004
Posts: 986
Massachusetts
Where I am the first CRA/Compliance Officer the bank has had, my goals appear simplistic they are as follows:
1. Develop a mechanism to report to the board information and format a way for the board to inquire with questions
2. develop a program to educate our customer base
3. assist in positive growth in the bank. This includes maintaining a strong relationship with customers and vendors.
4. watch the budget
5. ensure bank is trained (even though there is a training officer)
6. participate in community activities
7. Prepare a manual to become available in my absence that would be a guide for others doing my job in critical situations.

I thought these were very easy and attainable goals. From what I can see being a department of one I should be able to do all.

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#307741 - 01/26/05 11:25 PM Re: Compliance Goals
HRH Dawnie Offline
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Anchorage Alaska
Personally I'm big on quantifying goals (for instance, ensure bank is trained..in what? and how often?) Also, "participate in community activities" which ones? Are you focused on CRA for that goal or just any activity in general. Your goal may overlap another person's goal if you're just planning on hitting every heart walk in town

And then 7...the others seem attainable but what are you saying when you discuss a "manual"? Are you the CRA and Compliance officer? Because if so...that would be a lot of manuals I frankly couldn't leave a manual behind to cover me and I'm CRA only. Not to do my whole job. But what about all those other silly regs That's a whole lot of writing

CSB, keep that goal on the LAR/LR reasonable. I GUARANTEE YOU that during a data integrity exam there will be one error found. Even if you look at every single loan submitted (and that's EVERY LOAN to hit 0 errors) you're going to have something that someone disagrees with you.

I am known for pretty anal data integrity policies and still my goal allows for error, but far below anything that would cause a bank issues: (from my 2003 goals)

5. The Loan Register will be submitted by 02/28/03 with less than a 1% error ratio. A full audit of defined problem areas and a standard 10% sampling will ensure compliance with the standards set by our regulatory agency for submission. This review will be completed by 02/25/03 with corrections completed the following day.

That year we had a data integrity exam so I also added a goal to cover those results. Give yourself some breathing room
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#307742 - 01/27/05 05:40 PM Re: Compliance Goals
KAT Offline
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Joined: Aug 2004
Posts: 986
Massachusetts
The manual would only be for critical items not all phases. I don't do auditing but I have an outside auditor.

I am "assuming" that this is to list dates that must be met and how to do the things that must be done.

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