Is Anyone Paying Attention
At lunch one day recently, I decided to call a financial institution to ask a very simple question relative to an advertised account. Naturally I got the call center (as even calling the branch directly routes to the call center) and after tons of commercial messages about their long term CD special, their Instagram, following them on Twitter, liking them on Facebook, their App, their remote check capture, etc., I got back into the same loop again and again and again. This went on for my entire lunch hour as I sat my cell phone down to see just how long it would last.
In their viewpoint they were doing all these great things to communicate with me; yet, they could not pick up the phone in a branch to answer a five second question and kept me on a call center hold for an hour. These folks want me to like them on Facebook. I don't need to go on Facebook to tell you or them, I don't like them. They won't TALK to me. They just wasted an hour of my time telling me how they communicate with me and all they can do for me because they care about me, but they can't answer the phone! I am not important enough to TALK to.
Just in this past week I have had two very good BSA Officers tell me if I heard of a job opening to let them know. Both told me their management wanted to devote no resources (money or otherwise) to BSA, viewed any form of compliance unimportant and that the best relationship they had with their management was if they just stayed in their office and worked “alerts” and said nothing. Management basically did not want to hear from them. One told me her management would not even respond to an email from her. She told me, conversely, let the when the examiners come in the conversation is all about how her management cares about BSA. I hear the same scenario from many compliance officers on compliance. No one wants to TALK to them or even hear from them. I just finished a hearing a story about a conversion where the compliance and BSA officer were completely left out of the loop and told during the conversion process that they would be called if needed. I wonder who at that institution managing that conversion had ever heard of system functionality for BSA/AML software integration or reviewing new deposit disclosure formats and setup as examples of the multiple roles for these individuals during the conversion. This also makes the case for employing professional conversion coordinators to tie together financial institution conversions.
In my days as a consultant, my policy was that a client could always TALK to me. If not urgent, email, and I would respond that night as during the day I might be with a client. But if URGENT, CALL my number, and guess what, if I was not in a meeting, you could TALK to me. I didn't even have a message option. I still don't.
Thankfully all compliance or BSA officers don't face the scenario described above. Some are blessed in that management and the board do listen and TALK to them. But many are not so blessed.
Even the regulators are trying to TALK to financial institution management. But who is listening? I have heard how in the Bureau of Consumer Financial Protection Strategic Plan FY 2018 - 2022 there is no doubt that the regulatory environment is on its way out, till I am sick of hearing it. What part of such phrases as "implement and enforce the law" don't folks understand? How about Financial Institution Letter FIL 5-2018 dated January 10, 2018 on the subject of increasing credit and liquidity risk? The regulators are trying to TALK to financial institutions.
So people, pay attention! Pay attention to your customer communication needs, the communications of your compliance-related staff and the communication from your regulators. Fail to pay attention and the day will come when pay the price.