Take Some Time To Take A Fresh Look At Your Compliance Program
We are in the thick of summer and when things are this hot, it seems like time just moves more slowly. After you celebrate our nation's birth on July 4th, when the barbeque is gone and the fireworks have finished, why not take a little of this "extra" time to take a fresh look at your institution's compliance program. Here are six things to review.
- Your most recent regulatory and independent compliance examinations - Have your prior findings been addressed? Have, as corrective action, these findings been tied to your internal loan and deposit tracking and reporting processes, your internal Compliance Control Self Assessment Program, and your training for the coming year?
- Your Internal Compliance Control Self-Assessment Program - Has this program been tied not only to findings, but have outdated or lesser risk regulatory areas been purged and the program been updated to reflect process and regulatory changes since the last revision?
- Your loan and deposit tracking systems - These should tie to recent findings as well, but again, lower risk areas should be purged. Perhaps with increased review criteria, sampling should be reevaluated in terms of size and coverage. Is the program up to date in terms of completion and reporting? The key to the program is timeliness not only in terms of reporting but to curb recurrence. If the program covers too much volume and it not timely, perhaps a scope review is in order. Better one performed of a lesser sampling volume than one six months behind or one not performed at all.
- Your training - Again, has the training been tied to recent findings and upcoming regulatory events? Has the training been coordinated between internal prepared training and vendor prepared training? Is the training time to complete reasonable to ensure completion? Internal or external training that is too long and to cumbersome lacks effectiveness. Training that is so cumbersome as to be ineffective provides no usefulness.
- Your risk assessments - Have your risk assessments been reevaluated in terms of regulatory changes, product delivery methodologies, institution procedure specifics, recent findings, staffing changes, etc.?
- Your independent reviews for the coming year - Have they been tweaked to reflect regulatory changes and expectations and prior findings as well?
Taking time now to review your compliance program will help ensure you don't experience fireworks later on when they are not welcome! Happy Fourth of July!