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Dec 20
2012

COMPLIANCE OFFICER LAMENT: NEW YEAR’S RESOLUTIONS WE WISH OTHERS WOULD MAKE

Posted by Lucy Griffin in Lucy and Nancys Common Sense Compliance

Read Lucy's list and then add yours

 

*   *   *

Each New Year, as tradition has it, we make resolutions to improve ourselves.

 

Improvement can come by striving harder, refraining from overeating, making changes to life or working style. We may even decide to spend some quiet time with our families, away from Dodd-Frank and all the rest of what we obsess on the rest of the year.

 

It's all very well and good to work on ourselves.

 

But let's be  honest: When we really think about what would make things better, it often involves changes that someone else should make, right?

 

If someone else would change or do something differently, our lives would be easier, wouldn't they? 

 

So, how about it?  Here are some resolutions that a compliance manager wishes others would make. Anyway, these are mine, and I encourage you to add  your own. (Editor: Anyone posting one in the comment boxes between now and Jan. 2 will be entered in a random drawing for a $30 Amazon gift card.)

 

1. Consumers will resolve to read their loan documents, including the Truth in Lending disclosure, before signing anything.

 

2. Senators and representatives will resolve to read and understand all federally required mortgage documents.

 

3. All staff resolves to attend the compliance training for which they are scheduled--and arrive on time!

 

4. Members of the House and Senate banking committees will resolve to attend ABA's National Regulatory Compliance Conference and attend all sessions--even the early birds.

 

5. Consumers will also resolve to promptly review their periodic statements and notify the bank of any errors--and not wait for three months.

 

6. Cardholders will resolve to check with their children before contesting an ATM withdrawal.

 

7. Teenagers will resolve to pay cash for their sodas instead of using their debit cards.

 

8. Commercial lenders will resolve to attend all scheduled compliance training. They also resolve to listen and take notes. Better yet, they resolve to remember and use what they learned.

 

9. Consumers will resolve to refrain from writing their PIN on their credit and debit cards.

 

10. Examiners will resolve to use the compliance manager's contact list rather than wandering through the institution looking for people who missed training.

 

11. Examiners will resolve to discuss a "finding" with the compliance staff before deciding whether something is a problem.

 

12. Regulation drafters will resolve to learn about the practice they are regulating before they issue  draft rules.

 

13. The Consumer Financial Protection Bureau will resolve to make effective use of supervision rather than relying on enforcement actions.

 

14. The CFPB will resolve to give at least equal attention to nonbanks when scheduling examinations.

 

15. Reporters and journalists resolve to call companies by their correct name and types of companies, rather than calling everything financial "banks."

 

16. Consumers will resolve to learn that finance companies and mortgage companies are not banks and will use the correct company description before filing a complaint.

 

17. Mortgage brokers will resolve to ..., well, ..., um ..., behave.

 

These are some of my hopes for resolutions others would make. What are yours?

 

(Remember,  you  have up to Jan. 2 to write one in and be eligible for the drawing.)


  • About Lucy Griffin
    "Lucy and Nancy's Common Sense Compliance" is blogged by both Lucy Griffin and Nancy Derr-Castiglione, both longtime ABA Banking Journal contributing editors on compliance.


    Lucy, a Certified Regulatory Compliance Manager, has over 30 years experience in compliance. She began as a regulator, including stints with the Federal Reserve Board, the Federal Trade Commission, and the Federal Home Loan Bank Board. For many years she managed the ABA Compliance Division. Since 1993 she has served as a compliance consultant as president of Compliance Resources, Inc., Reston, Va. She is also editor of Compliance Action newsletter and senior advisor with Paragon Compliance Group, a compliance training firm. 
    http://www.ababj.com/images/stories/lucy_griffin.jpg

    1. In addition to serving as a Contributing Editor of ABA Banking Journal, Lucy serves on the faculty of ABA's National Compliance Schools board. For more than a decade she developed and administered the case study at ABA's National Graduate School of Compliance Management. She can be reached at lucygriffin@earthlink.net  

 

You can get word about these columns the week they are posted by subscribing to ABA Banking Journal Editors Report e-letter. It's free and takes only a minute to sign up for. Click here.
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Comments (9)add comment

Karen S. said:

Loan Officers shall resolve to make loans based upon loan policy instead of because he is a "good ole boy!"
 
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December 21, 2012
Votes: +2

Sandra Chastain said:

Loan Officers and Branch Managers will resolve to verify with the Compliance Officer before saying "sure, we can do that"

Branch staff will resolve to follow CIP Procedures instead of just saying "Oh, I've known him since he was knee high to a grasshoper"
 
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December 21, 2012
Votes: -1

Nancy Castiglione said:

Schools should resolve to teach useful financial education to our children instead of who was the king of France in the mid 12th century.
 
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December 23, 2012
Votes: +2

Cheryl Nakashige said:

The CFPB should resolve to minimize Federal Register proposals and final rule comments so that compliance officers don't waste time reviewing 1,200 page proposals for a 3 to 5 page disclosure.
 
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December 26, 2012
Votes: +2

Bill Jenkins said:

1. Our governemnt will resolve to recognize the futility of trying to protect consumers from themselves.
2. Check cashers, payday lenders and car title lenders will resolve to find an honest way to earn a living.
3. Consumers resolve to stop believing in a free lunch, the Canadian Lottery, Nigerians sending money from afar, and that they have just won a free iPad if they will only "click here."
 
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December 26, 2012
Votes: +4

Paul Jarosz said:

1. Loan staff will resolve to put credit files back in the files when they are no longer needed, instead of squirreling them away in their offices.

2. Commercial loan officers resolve to promptly forward documents relating to any adverse action loan requests to a designated central repository.

3. The first person who sees that a either a toner cartridge needs to be replaced, copy paper needs to be refilled or that there is less than a cup of coffee left in the carafe resolves to promptly rectify the situation.

4. Customers resolve to read every statement message. (Assuming that they also resolve to open every statement that they receive.)

5. Loan staff resolve to order a flood cert before a loan is made.

6. Loan staff resolve to provide accurate and complete data on HMDA data collection sheets. (Which assumes that the sheets are being provided for all HMDA-reportable loans.)

 
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December 31, 2012
Votes: +2

Linda L. Boyer said:

I shall resolve to take up running in 2013, so that I can stay at least one step ahead of the regulatory changes.
 
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December 31, 2012
Votes: +1

Sandy Simonson said:

Lenders will read their loan documents carefully before submitting them for processing, especially the attorney prepared documents.

All associates who remove collateral files from the vault will leave a tracking card filled out and notate removal in collateral binder.

The CFPB will stop teasing us with updates and only release information on final rules, especially HMDA

Congress will stop passing laws they have not thoroughly read or examined for compliance consequences
 
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January 02, 2013
Votes: +0

Dawn S said:

Management shall resolve to ensure adeqaute overight of vendors is in place rather than saying "that's what we pay them for."
 
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January 07, 2013
Votes: +0

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