Post deleted by kdlmit

The Law of Unintended Consequences tells me that the new procedures may have the ill effect of training the staff to disregard, or take less seriously, any communication that comes from you. Suppose your SCO is on vacation, and critical information needs to be communicated. You want to make sure that the staff takes the information as seriously as they would any communication from the SCO.

Another solution that would allow you to bypass this problem, as well as any us vs. them thinking is to develop (if you do not have one already) a company intranet where such communications can be posted by either of you.

There was another thread recently on training methods. HERE
My guess is that the SLO knows that his staff is overwhelmed right now with all of the refi's and such going on. Getting bombarded (no offense intended) with an overload of data, tends to drag an already overworked staff down even further.
Maybe you should talk with him and see if you can't work out a mutually agreeable system for information communication. I don't think you are losing your authority, at all.
Good luck, been there done that!
Maybe some of our resident lenders can help you out. "Calling all lenders"!

I don't believe I would have a problem with MY memo going THROUGH the senior lender or credit admin officer. But I would indicate that if I am requesting an immediate reply or response within X days, that timeline stands. But it would be a compliance memo, under the authority the compliance department has, based on its charter.

I agree with Andy. I wouldn't want compliance information to come from anywhere other than the Compliance Department. I work closely with each department in our bank and I do not mind if a department manager wants to have all communication with the staff funneled through him/her. I would, however, have a problem with non-compliance folks trying to communicate important compliance information. Maybe you can work out an arrangement where you provide the information to the department manager and he/she forwards it to the group.

Maybe the issue is that there are a lot of frivolous emails within the bank? Jokes, chain letters, and other non-work related emails all decrease productivity and may lessen the important messages that are distributed. Have senior management send out your bank's email policy concerning these messages and then have your auditor see if it's being followed. Once these messages have been eliminated maybe your messages will be read and followed a bit better.

I'm possessive of my writings. I want to be recognized as the author. I would not want a member of senior management taking a memorandum or some other type of communication and making it his/hers as though they composed it. I would also not want a person who does not know all the intricacies of a law or regulation deciding what should go into the email.

Additionally, I've always been under the impression that compliance, internal audit, loan review, etc. should be somewhat separated from those that they advise, audit or monitor.

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I'm possessive of my writings.

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I used to think that. Don't ever change careers to practice law--you get over that possessiveness real fast! Senior partners using your writing as theirs. Or if you are in-house--management using your writing as theirs. You have no proprietary interest in the writing.

In fact, as possessive as one might be about his/her writing--if it was done on the job, it probably does not belong to him/her.

You can look at this as a way of shifting some of the compliance burden to the actual "owners" of compliance for their departments.

What I do is send an email (blind copy myself) to the proper persons (department heads, etc.) within my bank and ask them to distribute the information to staff accordingly and ask them to copy me on their communications.

This way, I have proof that I have communicated information to the proper individuals as they are ultimately responsible for implementation of compliance for their departments. Win - Win. I keep my authority and so do they.

We also have an Intranet that we utilize to re-enforce information communicated to each area.

I agree with the SCO, based on the fact that the SCO - not the Compliance Officer, is ultimately responsible for compliance, although if he/she goes down based on compliance issues - you will probably be in the same basket.

The SCO is in the best position, as the supervisor, to know how to communicate with the troops. You have a right, under a separate reporting relationship, to a timely response to required communications, based on your input.

Who can best communicate with the line staff? It's always been the direct supervisors and the training staff with compliance training incorporated within that effort. Perhaps you should consider more formal training and less email to assure that your point of view is well known.

kdlimit,
Yes, you have been undercut. Nevertheless, this person's writing style gives you an opening.

If you can avoid opening with a sentence fragment, sounding pompous, lengthy sentences and burying the lead near the end of the paragraph, it will still be clear which e-mails you wrote. More importantly, they will actually get read.

There are several issues involved here, but to answer your question, IMO your authority is not intentionally being eroded. a quick band-aid has been applied as temporary relief, to a problem, but a solution to that problem has not yet been effected.

There is a stated saturation of e-mails being sent from varying sources regarding the changing and implementation of bank policy. The individuals sending these e-mails are not coordinating there efforts with each other and the branches are probably being inundated with requets to take action or report information about a number of items, all within the same time frame. This can be frustrating to those receiving the requests.

Someone has elected to resolve the problem and has come up with a plan to try and coordinate action requests of branch personnel. IMO its not an effort to dilute authority. I am also sure that each of the other Dept's or individuals feel that there e-mails should not have to go through a central point either.

What this sounds like is a problem was voiced and a decision was made to centralize e-mails without input from all effected by the decision.

Once the Loan Administrator has to deal with the same volume of e-mails as the branches were, I have no doubt there will be another change, as that person will soon determine they don't have the time to screen all the e-mail either. This should result in doing what should have been done in the first place and that was to open discussions on how to improve the internal system from the folks that use it.

Well I'm glad I'm not alone because the same thing happened to me. I can still communicate with a limited number of department heads, but communication to the branches has to be "vetted" through channels.

Yes - it slows down communication of what I consider are important issues. And yes, I feel I am not as effective as I can be. All I can do is keep a record of what I communicated, and to whom. If the s*** hits the fan later on, I'll use those records to duck and cover!

I am sure that a lot of banks will have to resort to something soon to cut down on personal emails, chains, etc. (they better keep their hands off my BOL!!), but your bank happens to be leading at the moment.

It sounds as if your bank had some compliance issues in the past, therefore, there may be some positive effect to this in that the lenders will be getting a message from the senior lender that compliance is important and is part of the job. That is, of course, if the SLO really is on board with compliance. Others here have had some very good suggestions for you, i.e. the blind copy of your email. Good luck, this may be temporary.

Sounds to me like they are being bombarded with memos that do not pertain to them.

Have you ever received a copy of a mass communication and wondered if it even pertained to you or your department? At least with the SCO issuing the memo, they will know that the communication pertains to them, as the SCO can weed out communications that his/her area does not need.

In a way, I agree with the SCO. I would not want anyone else telling my employees that they have to do something without first explaining it to me. After all, they work for me and not for the compliance officer. I should also be versed on the issues so that if someone has a question I can adequately address it.

And, if you are possessive of your directives, send your memo via email to the SCO so you will have proof that it came from you. You could most always manage to copy another person, for instance your supervisor, so that there is another person that knows the directive actually came from you.

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Poisonous without being rude

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They can put that on my tombstone.

Does it seem to anyone else like this whole compliance thing is really stressful and maybe we should all find different careers for the sake of our mental well-being?

Anon, look at the Frivolity threads.
You are correct, the job has made us all nuts (never mind the squirrels). Thread

We are a bank of $350 million. Sometimes compliance gets bypassed. It only takes one memo to go out that will violate a compliance regulation, I march myself to the President's office, explain why we can't do what they are trying to do, and sure enough everything has to start being blessed by compliance again. Sometimes I have to wait a couple of weeks, but it always happens so I just set back and wait rather than fight the battle upfront. Works for me.

Thanks to all who responded. Your comments and advice was very much appreciated. I guess I was upset at the time. You have to know this person; he is the type that questions everything I say. When compliance concerns lending, I have learned when I approach him to show it to him in black and white.

One thing to consider is that that other person may also feel as though their authority was threatened. Work with them, not against them, and be right. That will build up both a cooperative attitude and confidence.

It is always easy, it just is always...