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Wednesday, June 12, 2013

A Wave of Compliance Manager Duties Crashing Down On You?

Compliance Manager - Mission Impossible?

Of all of the groups benefiting from the wave of regulation, one has created the hottest job in the industry today -  the "Compliance Manager."  If you wear the "Compliance Hat" you know that this is just the industry looking for another panacea - a silver bullet to manage the seemingly overwhelming task of keeping up with the rules and regs tsunami.  If you are a company owner or manager, you WANT a silver bullet (if not to just shoot yourself with!)

Reading the job descriptions in association with the Compliance Manager job posting, you would think the job is kind of amorphous; alot of "and other duties as may be assigned in order to comply with regulations..", or "and other regulatory requirements..." To me that is an anathema to the position.  We want to be as specific as possible about the job duties.  We need to specify WHAT that individual needs to do AND when.

A Simple and Practical Approach

Checklist of compliance manager duties and timing
What are the duties of the Compliance Manager?  This rubric attempts to manage the responsibilities in a finite way. Click here to add comments and suggestions to the sheet. 



We have seen a substantial growth in "Compliance Management Software", too.  This is a reaction to that same search for panacea.  Even with automation of data management, audit and reporting there still must be someone to parse the data and verify its timing and accuracy.

Since it's the human process that makes the program effective, we have upgraded our compliance manager position description to include these elements.  This also ties in with all of the requirements of the CFPB audit guidance, so that if you are anticipating a CFPB examination ensuring you have implemented.  If you are a subscriber to the updates you can get them on our Document Management Website.

5 comments:

  1. There has not been a mention of PFQC or the newest guidelines from FNMA about post closing audits

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    1. That's an excellent point - where do the compliance manager's responsibilities with respect to quality control begin and where do they overlap with the Quality Control manager's responsibilities?

      I see them as two functions operating separately but in coordination. The Regulatory Compliance Manager has a responsibility for insuring that all of the compliance elements (disclosures, tolerances) have been addressed in the QC process. We have compliance sections in each of the Quality Control Audit rubrics (Pre-Funding, Post-Closing, Annual and Servicing).

      Maybe there needs to be a more specific reference to these functions within Compliance Management? Excellent feedback!

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  2. Besides over-seeing the initial and ongoing AML training for employees, most AML policy manuals require the AML Compliance Officer to additionally take advanced or specialized training (online, seminar, etc) annually, to keep up-to-date on AML issues.

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    1. Perfect. So I need to add a section for Continuing Training for the compliance manager. You mentioned AML, which I was aware of. How often do you think? FINCEN says semi-annually, wo that is a good benchmark. What about other training, like Fair Lending enforcement?

      Great comment Larry!

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  3. Adding disaster recovery plan review annually as a compliance manager duty.

    I'm finding that Vendor Management is the biggest concern for compliance officers - far more so than the actual regulatory compliance officers. In the Vendor Management plan we have drafted, we do include that disaster recovery is a requirement for the vendor at approval and annually.

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