36 Hoosier Banker June 2015 DIRECTORS / SENIOR MANAGEMENT What’s your community bank’s compliance culture? It’s a question regulators are asking more often these days. Examiners increasingly want institutions to demonstrate a strong commitment to compliance, from the board of directors down to the rank and file. How do you create that culture, though? Culture is an elusive concept, but compliance-minded community banks often share several traits. Among successful institutions, adhering to these five principals is key: 1. Compliance is pervasive. Compliance must be an entrenched part of a community bank’s daily activities, at every level. In institutions where compliance is prioritized, the compliance officer doesn’t sit in a back office, to appear only when trouble occurs. Compliance personnel instead take an active role in all areas of the business. They are active participants in strategic planning meetings, so that regulatory factors are taken into consideration at the forefront of determining the bank’s growth plans, budget and other long-term items. 2. Compliance is invisible. In the best-run banks, it’s not obvious that compliance is happening. It’s simply embedded into the work process. If a loan application requires a compliance-related step, it’s not considered to be an unnecessary burden, it’s just part of the loan application process. Automation can help make this happen for many institutions, essentially placing many compliance functions on autopilot. 3. Change is embraced. Banks with a strong culture of compliance enjoy a dynamic environment. They don’t look at new regulatory changes as roadblocks to progress. Instead, they adapt. It’s a mindset that recognizes compliance as a valuable aid in ensuring the bank is conducting business in a safe, responsible manner. Given today’s fast-paced regulatory environment, banks can better achieve this goal by adopting standardized approaches. When a bank has systems in place to deal with change, it’s easier to successfully manage regulatory curve balls. 4. Compliance is seen as a smart business decision. Too many community banks approach compliance as a check-box exercise. It’s tedious and done only because it’s required. However, when an institution has a strong compliance culture, compliance is considered a strategic business advantage, not a burden. Compliant institutions gain a better perspective of their business as a whole, including strengths that can be leveraged and weaknesses that can be remedied. They also avoid the time- and cost-intensive hassles associated with enforcement actions and other penalties. 5. Outcomes, not obstacles, are the focus. Where compliance culture is strongest, the focus is on business goals, not the compliance hurdles that might stand in the way. Leaders at these institutions ask themselves: How can we best meet our objectives in light of the regulatory requirements, and how can we do that most efficiently? Compliance isn’t ignored, and the business goal isn’t sidelined. Instead, the community bank finds a way to generate compliant versions of its desired outcomes. Cultural change can be a struggle. It takes time, and it requires the buy-in of employees at all levels. However, community banks that take the time to foster a strong culture of compliance will see tremendous benefits that not only please regulators, but also strengthen their business as a whole. t Five Secrets to Building a Strong Compliance Culture About the Author Pam Perdue is executive vice president, regulatory insight, for Continuity Control, New Haven, Connecticut. She previously served as chief compliance strategist and has more than 20 years of regulatory industry experience. A graduate of The Ohio State University, Perdue has worked as a federal examiner, chief compliance officer, educator and consultant. The author can be reached at 888-932-6759, ext. 201, email: Pperdue@continuity.net. Continuity Control is an associate member of the Indiana Bankers Association and an IBA Preferred Service Provider.
RkJQdWJsaXNoZXIy MTg3NDExNQ==