By now, many of you have taken the leap in hiring compliance managers, compliance personnel and general counsel. What you may not have realized is that although they are in charge of guiding and monitoring the company, everyone in the company is in charge of compliance. Part of a great compliance management system is ensuring that each employee is not only trained on the policies and procedures of the company, but also, that they execute them as part of their daily job. You will not have a successful examination unless each person understands this concept.
During the exam process, you will be asked for an enormous amount of information regarding your policies and procedures. No matter how pretty they look, the CFPB will take the time to talk to your employees and ask them specifically about how they perform certain functions. Their answers need to align with the policy and procedure that you have in place.
Next, each employee should understand that they are in charge of compliance too, and if they see others stepping outside the boundaries of your policies, then they have a way of reporting this anonymously. I know that no one likes a “tattle tale”, but in today’s environment a compliance person cannot be in all departments simultaneously. Each employee needs to take compliance seriously enough to report continuous issues, and each employer needs to provide a safe environment for making this known to management. Otherwise, you have things happening in your shop that may cost you a lot of time and money.
Successful compliance managers are using training and testing, and documenting those results for each employee. They are then setting up a system to bump up any problems to compliance management so that they can be reviewed and action can be taken. This is a comprehensive part of your compliance management system and one that will make you look really good to the examiner!
More accountability for each employee will be the new “norm”. The days of ” I was just doing what I was told” are over! Nice article.