During a crisis, the future outcome of your compliance program can go one of several ways. It can get worse, it can stay about the same (which is the most unlikely option) or it can get better. While this unprecedented time presents its own set of challenges, it also brings with it an opportunity to focus on building an even stronger culture of compliance.
As firms continue to manage their compliance programs remotely with distributed resources, it’s more important than ever, to foster a culture that’s focused on maintaining the continuity of your written supervisory procedures. This is especially true with so many employees spread out, working remotely, probably for the first time.
In a time where compliance officers are unable to walk the floors or easily implement ‘paper-based’ operations, this article offers three tips to strengthen the foundation of your culture of compliance.
Don’t be Afraid to Pivot Compliance Processes
It’s likely that some of your compliance processes have needed to change due to unavoidable effects of the current economy – and that’s okay. What’s important now is not to regress, but instead move towards change and create a plan for the future. If your company views change as a room full of lasers to maneuver through, it will naturally feel that way. Instead, making updates to your processes and procedures should be viewed as an opportunity to implement more effective, efficient alternatives.
Take, for example, the internal audit process. It’s unlikely that your audit team will be heading into the office to conduct a branch inspection at this time. However, we’ve noticed an uptick in clients utilizing the pre-audit checklist section of our branch audit tool to get as much work done before the actual audit is scheduled to take place.
Use your consultants and technology providers as a resource to help you respond, recover and thrive in the face of this disruption to “normal” compliance processes.
Stay Current on Rule/Policy Changes
Both state and federal regulators have recognized the need to provide relief to firms affected by the COVID-19 pandemic, relaxing certain rules and expectations in recognition of the unprecedented challenges businesses and their workforces now face. However, this will not give businesses a “get out of jail free card” for non-compliance.
In the weeks and months to come, your compliance team will need to reevaluate its regulatory framework, programs and policies, with an eye on what has changed due to the current situation. It’s important to understand that changes in the laws affecting your firm are ongoing and ensure that you have the means, whether in-house or outsourced, to stay up-to date on those changes. Ensure that your policies continue to reflect those adjustments (temporary or not) and that you properly communicate that to your employees.
Constant Communication and Training is Key
The final element to building a culture of compliance is making sure that everyone at your firm – even your third-party vendors and partners – are aware of your commitment, understand the rules, and know where to go if they have a concern.
Communicating your commitment is important, but training is vital. At the end of the day, the majority of your workforce wants to do the right thing. But to do that, they need to have extremely clear expectations about the role they play in maintaining a culture of compliance. During this time, be more focused on over-communication, versus under communication.
Each week, take on a large, substantial compliance issue – like social media or client data protection – and tie it back to how your firm expects its employees to comply. Maybe your rules haven’t changed since moving remote. Great, communicate that. Maybe they have. Perfect, now explain how. Even if in the back of your head you’re saying to yourself “they should already know this;” assume they don’t. The more you communicate, and train on, compliance – the more success you’ll see in the future.
