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“The five steps in teaching an employee new skills are preparation, explanation, showing, observation and supervision”- Bruce Barton

If you think you have a hard time keeping up with changing regulation, consider the plight of your sales and operations staff.  They are not in all of the meetings, conferences or webinars that you attend.  They simply know what procedures you would like them to follow; yet most don’t understand why.  They are also under direct management that may not know why either. This may cause the managers to ignore the procedure or just do it the way they have always done it. Unless you live their life on a periodic basis, you will never know what they are doing right and what they need to improve on.  Improvement takes time, is incremental, requires constant reminders and training. Management of compliance is not only about setting rules of conduct.  It is also about living those rules with the people who have to implement them in the field.

In Lean Six Sigma world, we call this the “Gemba Walk”.  Gemba is a Japanese term for “the real place”.  Walking in “the real place” means you are watching and observing the practices and procedures you have put in writing.

Quick Hit Tip #9-Walking the Gemba

Gemba walking means that someone who is really familiar with compliance, spends some time just talking to people in operations, sales and branches about what they do and how they do it.  It DOES NOT mean showing up, scaring everyone and checking to see who is doing things wrong and then writing them up.  Geez folks, no wonder compliance gets a bad rap!

To understand this process, take a moment to understand that everyone in your organization, including the C-suite, is in a constant state of learning, as we transition from little regulation to a lot of regulation. I would venture to say that even the compliance people are in a constant state of learning, interpretation and even confusion.  Then get into the mindset that we’ve been doing business the same way for over 30 years and teaching old dogs new tricks is, well, tricky!  People don’t like change!

Okay, good!  Now you have the right mindset to do the Gemba Walk.  Once in a while go to a department or branch and just ask them to show you what they do.  Even offer to assist them so that you understand what they do.  Then look at what they do and how they do it.  Having done this, myself with countless companies and their branches, I’m going to guess that for many of you, your head spins around and blows off of the top of your shoulders (this is why I have a spring for a neck J)!  For it is during this time that you will see just how well the policies and procedures of the company actually work.  You may also see how each branch does things a little differently and many times those different ways are not compliant.

So why is this important?

  1. The examiners will walk the Gemba with your employees. They will ask them how they do something, maybe even request that they show them and then put this in your examination report.  It works something like this:  You have a procedure.  The examiner asks someone how they perform that procedure.  They then see if the procedure matches your workflow diagram and written procedure.  Your goal is to make this happen BEFORE an examiner visits your shop.
  2. Training is not a one shot deal. One of my favorite phrases is “repetition is the mother of learning”.  Someone may sit in a training class, pass the quiz and still not take that knowledge back into their practice.  Your job is to make sure the training sticks so that things are done compliantly.  If not, then more training needs to occur.  This is a never ending process but one that is essential.
  3. Many of your branches do their own thing. That may have worked when no one cared, but the CFPB now cares and so should you if you want to avoid issues.  The stories that people tell me about branch activities is downright scary; and I can assure you that it is highly likely those practices do not align with the company policy.  It’s true, go check for yourself!
  4. You will learn what works and what doesn’t in order to make your procedures more consumer and staff friendly while staying compliant. Just because a bunch of people sit in a meeting and come up with the greatest idea, doesn’t mean that it will work.  If you don’t have someone who does that job in that procedural meeting, then you missed a great opportunity!
  5. Don’t do evaluations, score cards or report cards as part of this interaction. No one wants to be judged, and if they think you are there to evaluate them you will lose the trust that you need, in order to figure out if something is wrong.

As a final reminder, you are not there to judge the person performing the task.  You are walking the Gemba to observe how tasks are being performed, and whether they align with your policy.  You also want to observe if your policy makes sense.  Maybe it needs to change based on your observation.  Discussion about how to fix what is being performed, versus what policy really is, will be done after you have the facts!

If you need someone to walk the Gemba, teach the Gemba to your management staff or help you set up an evaluation program,

I’m just a phone call or email away!

If you missed the previous quick hit tips, they can be found on this blog.

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Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

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