Advice to New Compliance Officers By Aubree S. Rehmke, CRCM, Consultant, Vantage Point Solutions I have spent my entire career working for financial institutions. After graduating from college, I started as a teller and quickly transitioned my way through several positions, spending the majority of my profession as a compliance officer and BSA officer for a small community bank. Today, I work as a consultant with Vantage Point Solutions, performing audit and consulting services for small to mid-sized financial institutions. Over the years, I have met many novice compliance professionals, and one commonly shared frustration I hear is that they aren’t sure where to start. In the span of almost 20 years, I have learned many lessons (and have made many mistakes). I want to pass that knowledge on to those who may be lacking the mentorship that is essential to navigating this role. So, if you are reading this and are new to compliance management, here are my two cents on the things you can do to make this job a little easier for you. Get Organized Compliance officers are expected to know and manage a considerable amount of information, from policies and procedures to consumer regulations to monitoring and training. Therefore, it is extremely important to build a compliance management program, or what we in the profession sometimes call our “house of compliance.” Some institutions have the luxury of purchasing software to help manage the compliance function. However, if you are like me and do not have that convenience, then you may need to build your “house” from scratch. It works best for the compliance department to maintain a folder on the institution’s network or intranet where all the electronic compliance-related items are stored. For ease of use, this “house” can be organized in such a way as to include a separate folder for each of the pertinent compliance areas, for example: 1. Board and Management Oversight: Used to house all of your board reports, requests for approval, compliance committee meeting minutes, etc. 2. Policies: Used to store all the institution’s approved written policies as well as the annual policy reviews and amendments. 3. Procedures: Used to store all of the institution's written procedures. Consider breaking this down by department, then by task or function. 4. Risk Assessments: Used to house all of the compliance-related risk assessments, organized by annual review year or by type of assessment. 5. Monitoring and Auditing: Used to store ongoing monitoring functions performed by the compliance and/or BSA role in addition to third-party compliance audits, self-reported violations, corrective action, remediation tracking, etc. 6. Training: Used to store compliance training organized by year or topic in areas such as online course assignments, handbooks, materials, employee acknowledgments, board training, etc. 7. Consumer Complaints: Used for all consumer complaints, incidents, investigations, logs, responses and management reports. 8. Change Management: Used to store the tracking of new or changing regulations, products and services, and new business processes or strategies. 9. Regulatory Exams: Used to store regulatory exam information, request lists, collected exam documents, exam reports and corrective action/remediation. 10.Compliance Library: Used to store tools, news articles, agency notices, FAQs, checklists, worksheets, flowcharts, training materials and any other resources you have collected over time to aid in the compliance officer role; organized by topic or regulation. Now, obviously, this is just one way to do it. In my experience, this folder system ran like a well-oiled machine after the initial setup. After you create some kind of organization for your electronic house of compliance, you will be more efficient and find it easier to locate important documents and other resources. If you have inherited the previous compliance officer’s folder system, consider taking the time to reorganize it into a structure that will work best for you and your organization. Create a Project Tracker With so many different projects occurring at different points throughout the year and at different frequencies, consider maintaining some kind of project tracker. Again, if you are not using software to assist in managing this function, I highly recommend an Excel spreadsheet and/or setting calendar reminders or tasks. The tracker or calendar can be comprised of all the different compliance 30 | The Show-Me Banker Magazine
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