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Looking for the Answer

By Elizabeth Greene 23 Jan 2019

Finding the right answer to your regulatory question can be a daunting task. With the wonderful world of the internet at your fingertips, there are several areas where the best of intentions can produce the worst of results. Simply "Googling the answer..." can subject you, the researcher, to a dark web of incorrect information, misdirection, and regulatory risk. So how do you use a resource, like the internet, in a way that is safe, legitimate, and practical when seeking the regulatory answer to the concerns you address on a daily basis?

 

The first step in doing this is to recognize a legitimate, trusted resource, while a solid secondary step would be gaining an understanding of how to navigate to a trusted source.

 

Is your online search giving you a regulatory website or a blog? Is it the correct regulation? Is that blog trusted? The bottom line is that you, as a compliance professional, will ultimately be responsible for the guidance that you follow; so, it is critical to ensure you are using the most legitimate resources.

 

There are several trusted websites handed down to the banking industry directly from the government. More recently, the Consumer Financial Protection Bureau (CFPB) has come into the mix as a leading regulatory authority. The CFPB developed its website as a reliable and comprehensive resource for guidance and regulatory information. A table of contents is in place on their website, listing the details of their regulations along with definitions, bullet points, and explanations. The Federal Deposit Insurance Corporation (FDIC) has similar resources available to the public, itemizing which regulations they monitor in regard to financial institutions. Additionally, banking professionals can find blogs, training programs, and resources on various topics within the industry on both sites. Similar resources can be found for the Board of Governors of the Federal Reserve System (FRB), Financial Crimes Enforcement Network(FinCEN), Fair Credit Reporting Act (FCRA), and many more.

 

Outside of the above mentioned resources, the internet also affords us the opportunity to connect with the banking community at large. Use of those resources is encouraged, but do not solely rely on them. Here, you will find blogs, community chats (commonly referred to as "Forums"), or regulatory conversations being had. Topics within these resources will not be regulatory certainty, but, rather, may be opinions handed down to our industry. Nevertheless, these resources can be used as a roadmap to where the cited information can be found. For example, if you were to go online and simply type "TRID Guidance" into your search engine, you receive a list of available resources right at your fingertips. Study these links. Where are they guiding you? Some are direct links to information from the CFPB, but, are they regulations? Blogs? Forums? All of these resources will appear, and it is the responsibility of the user to determine how this guidance can lead them to the correct result; ultimately making an informed decision. Analyzing and knowing this information can be fundamental in finding the information you need to make an educated, rooted in documented evidence, regulatory decision.

 

Ultimately, when relying on information found online, the user should keep in line with the regulations set forth by the government. Once this regulation is located, a correct and accurate interpretation should be made. Here is where subject matter experts should be utilized and relied upon. Having a strong group of certified compliance professionals will afford you the proper understanding of how to adhere to regulatory guidelines. Bringing what you have found online to these professionals for interpretation and guidance will afford your institution the continued growth and success in complying with the many rules and regulations set forth by the government. A strong compliance group should also have resources available for you (e.g. Regulatory citation, articles, training resources, etc...) that allow you to make an informed decision. Use of these resources will allow your group to make sound, risk-based decisions for your institution.

 

A sound, risk-based approach to researching regulatory information online will be critical to comprehensive decision-making. Although there are many resources available, not all information found online will be reputable information and can lead to misdirection, opening your institution to risk and non-compliance. Continued reliance on your compliance professionals for accurate, risk-based interpretations of the regulations, will ensure continued success in an ever-changing environment.

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