Tackle the ‘500-Pound Gorilla’ That is Compliance

By Steve Gibbs

Implementing and monitoring compliance programs can be a daunting task—a “500 pound gorilla,” if you will.

Some of us have begun to recognize the “gorilla” and look it straight in the eye. However, as any trained animal handler will tell you, once you’ve looked a beast in the eyes, never turn your back on it!

Of course, this means that a functioning, controlled compliance program will require ongoing review to prevent “turning our back” on the program. So where do we focus?

Why, of course, the foundations on which the program was built:
* Compliance officer;
* Compliance policy;
* Products and services; and
* Resources and tools.

At a minimum, the following questions should be covered for each of these foundations:

* Compliance officer. Does this position have sufficient authority to fulfill obligations of the job? Does management allow the compliance officer sufficient access to various departments, supporting compliance objectives and goals? Is the compliance officer aware of new products and services within sufficient time to determine compliance impact and respond accordingly? How much of the compliance officer’s time is spent purely on compliance (if other duties exist)?

* Compliance policy. Are policies reviewed on an ongoing basis? Are directors educated as to the reasons for and effects of policies as they are presented? Are policies reviewed with the departments or areas on which they will have a direct impact?

* Products and services. Are risk assessments performed for each product and service to determine potential compliance issues? Are new products and services presented to the compliance officer for review prior to adoption? Are existing products and services being consistently re-checked after changes in laws or regulations?

* Resources and tools. Are sufficient resources and tools available to accomplish the compliance agenda? Is the compliance officer using training as an effective tool to maintain and reinforce compliance materials? Are materials being updated for changes? Has the credit union budgeted for information systems or software to address increasing needs?

These are questions of the most basic nature. Credit unions should develop review questions and programs based upon their size, complexity, and level of change experienced within the organization.

Remember, never turn your back on a “500 pound gorilla.”

Steve Gibbs is assistant vice president of the Texas Credit Union League’s Shared Compliance Resources. Contact him at 800-442-5762.