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Answer by Andy Zaviona: Seriously consider a good compliance school. Either at the state or national level. The ABA school is at the end of October. It does little for you on a state level, however it is very well recognized for its national program. (Disclosure: I am on the school board.)
This basic school provides the indepth insight needed to start you on the successful path of being a compliance professional and starting a strong program. Short of a weeklong school, look for shorter seminars and webinars available live or on tape, that will provide you the expertise needed to gain the confidence in you needed to support your staff and board. Their confidence in you will translate into real dollar savings and proper time management. Prioritize these classes based on your needs, lending, operations or specific tasks like CIP. The regulations are changing and you are getting into this at a busy time. Hopefully you can dedicate your time properly, to prepare for the changes ahead.
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Answer by David Dickinson: Andy's provided some good information. I would also begin reading the posts here at BOL daily. Get signed up for the briefings, which are emailed to you, here. Good luck.
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Answer by Ken Golliher: You can't learn everything at once. Prioritize the topics which you need to assimilate. Focus on "bet the bank" issues such as Regulation B, Regulation Z and Bank Secrecy Act and the current issues Andy mentions. Review your institution's most recent compliance examination, particularly the areas of prior criticism. Make certain that all prior criticisms are fully remedied; repeat criticisms are a bad thing.
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Answer by Richard Insley: In addition to the excellent recommendations above, contact OTS and establish a relationship with your region's review examiner(s) and managers. Ask the same question you posed to us. Also ask for the following:
- a list of the most common vios cited by OTS examiners during the past year (or any other convenient time period)
- a copy of the most recent compliance examiner's notes from the exit interview with your management (not all of these items will show up in the formal exam report)
- OTS's assessment of the top 5 regulatory issues for thrifts during the past and upcoming 6 months (CIP and HMDA will be there, but what else does OTS consider to be critical?)
- any other material or suggestions OTS may be able to provide that will help you develop an action plan
- anticipated date and scope of your next compliance exam
- OTS' expectations for staffing and resource commitment for compliance management in a thrift of your size and complexity (if you don't have enough resources, make noise NOW not after the 2004 budget is approved)
If you are new and the thrift was without a C/O for a period of time, determine whether you already have an implementation crisis for the two major deadlines that are approaching: CIP (10/1) and HMDA (phasing in as early as late November). These projects are critical. If you have ANY doubt that your thrift will meet these deadlines, you should bring in help ASAP. Both of these regs are regular sources of serious enforcement actions and huge penalties. The cost of an expert helper will be small compared with the cost of punishment later.
First published on BankersOnline.com 12/1/03
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