If you are the compliance oﬃcer in your institution life is good; better than it has been for a lot of years. You have successfully implemented all of the recent regulatory changes and there is nothing of signiﬁcance on the horizon. Put your feet up on your desk, lean back and relax….or not. For a compliance person there is always plenty to do and it does not take much digging to ﬁnd it.
First, do you have all of the policies and procedures that you need and are they up to date, or is there one tough one you have been reluctant to tackle? Recently, we have talked about the importance of policies and procedures and how to write them. I can almost promise you that your policies and procedures need some work and some tweaking.
Second, review all of your account disclosures and if they are prepared by a platform automation system, the systems that are generating them. Have there been any changes in the products that your institution oﬀers since the time of your last review? Are the product descriptions in your document preparation systems identical to what management thinks that the product is? More importantly, is it the same as the product description in your account servicing systems? I once worked with a bank that was disclosing that there was daily compounding of interest on its interest bearing deposit accounts but its account servicing system was set up for monthly compounding. You don't want to have to go back two years and reaccrue 2000 deposit accounts.
If you have not done so in the recent past, review the capabilities of your institution's automation systems, particularly your core processing systems. They contain tons of information about your institution and about its customers. Your systems also most likely have a report writer of some type that can pull from those systems information that would be valuable to you in doing your job. Automation systems are one tool that most compliance oﬃcers are under using simply because they are not aware of the capabilities that are there.
In one of my prior articles, I suggested that a compliance oﬃcer should make at least one suggestion to senior management each month on how to improve the proﬁtability of their institution. When you are reviewing the products your institution is oﬀering keep in mind how minor tweaks could be made to those products to make them more proﬁtable. Here is an idea. Have your institution quit buying ball point pens and wooden pencils. First, everyone already has a pen and a pencil and you don't need two. Second, pens and pencils are breeders; one day there is one in your desk and the next day there are ten. How did they get from the stock room to your desk? Most of them probably end up in the book bags of the employee's children. That will probably only save two or three hundred dollars a year, but it's a start.
You better than I know the things you need to do. One trick that works is to put the most distasteful thing that you have to do at the top of your "to do" list and then don't go to the second item until you have accomplished the ﬁrst.