Moving Beyond the Compliance Commandments

Compliance is full of "thou shalt's" and "thou shalt not's". This kind of command may be useful on stone tablets, but it doesn't prove to be the strongest motivator for employees. All too often, the response to a compliance training program or memo is "if I can't do this and I can't do that, what can I do?!?" Without a reasonable way to get the job done, bank staff will reject compliance as too difficult, ridiculous, or downright impossible.

Converting regulatory requirements into no-no's is not the most difficult challenge. Converting regulatory requirements into getting a job done correctly is much more difficult. Training - and compliance procedures - should be aimed at how to do a job in a way that is in compliance. Training that simply issues the compliance commandments will leave people puzzled. Worse yet, it leaves them to figure out how to do the job - and their methods might be creative but less than accurate.

The secret to good compliance training is to do more than recite the rules and prohibitions. The secret is to build compliance into the job. If you do this well, bank staff should do the right thing without knowing whether they are complying with a particularly pesky regulation.

Needless to say, off-the-shelf training programs can save you a great deal of time and effort. But to get outstanding results using off-the-shelf programs, you need to do more than turn on the video machine. You need to find ways to tie the program to what people need to know. Set out below are some ways to make compliance training make more sense - and stick.

Compliance Training Tips
Train for the job rather than for the regulation
This means that before training - and before developing procedures - a team has to concentrate on how to build compliance into the job. When a team is involved, they develop ownership in the product - the procedures and training program. This gives the compliance department some allies, and perhaps even some people to help with the training.

Involve staff in the training program
Lecture is necessary, but other techniques can enrich the class. Try using several techniques for involving the group. This could be something as organized as an exercise or a case study. But you can also use more spontaneous methods such as calling on people and asking what they think. Not only does this technique keep people awake; it often results in some creative ideas; including better and more efficient ways to do the job and comply.

Use more than one teaching technique
Let's face it. We have to do compliance training over and over and over. We need to have ways to vary the training to avoid becoming routine. Plus, different people learn in different ways. Some respond to lecture while others tune out. Some like to learn in groups while others like to study solo. Computer and video training are useful and efficient. But you can still use other techniques to supplement them. Handouts, problems, quizzes, and discussions are all ways to vary the delivery of the message. The more ways you can deliver the message, the more places it will stick.

Use reality
Nothing sticks in the memory like something that really happened. Collect examples of a compliance challenge, such as the customer with 7 checks totaling $12,973 or the customer that may have been structuring. Reality strengthens the message. Ask designated people (or everyone) to bring a situation to class. Discuss the problem. Whenever possible, have the full class work on a solution to the problem. This makes them think through the issues with you to guide them. It also gives them ownership of the solution.

Train in between training
The biggest drawback to training is that people tend to forget. Find ways to reinforce the information imparted in training. Use techniques such as an open-book problem. Make it easy and cheap by using e-mail with a required response. Or insert it in the bank's newsletter. Also use staff meetings to slip in some compliance information. Bits and bytes may keep people current.

Reward good performance
While report cards may not be a welcome idea, some judicious recognition of good performance can encourage people to try harder. Nothing motivates like the chance to be recognized.

Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 15, 12/00