Compliance Blog

Posted by Anthony Demangone

Today marks the beginning of NAFCU's annual Regulatory Compliance School.  I'll be the master of ceremonies this week, and I'm also delivering 11 talks.  They'll be sick of me by week's end.  With that in mind, I've pre-written this week's blog postings.  The topics will not touch on recent regulatory actions.  Rather, I'll address general issues that should be of interest.

Today, let's talk about compliance certification training events.  NAFCU offers the chance for interested persons to achieve the designation of a NAFCU Certificed Compliance Officer, often referred to by its acronym - NCCO.  It is open to anyone - NAFCU members, non-members, attorneys, consultants, and vendors. The school covers a lot of ground.  It is designed to provide a foundational overview of all-things compliance. To earn the NCCO, attendees must pass all four tests to obtain the designation. 

Keep in mind that NAFCU is not the only organization to offer this type of certification program.  Which program is right for you?  That's a business decision that you are more than able to make.  But here are some thoughts about the use of certification programs.

1. They are pretty darn useful.  If you have someone who is new to compliance, these programs are a great way to show them all the complexities that exist.  I understand that the costs of on-site training can be substantial, but I believe that a good certification can actually save you money in the long run.  A compliance officer is only as good as his or her training, resources, and experience.  By making the investment of a certification program, you are going to get a ton more work out of your compliance officer. They'll be able to spot new issues, and they'll be more efficient at their day-to-day job.
2. Once is good, but two times is twice as nice.  You've hired a new compliance officer.  Perhaps you promoted a cracker-jack teller.  Three weeks after the hire, you send her to compliance school.  You're all set, right?  Not quite.  Compliance certification programs are tough.  They are akin to drinking water from a fire hose.  A compliance newbie will certainly benefit from the program, but it is a lot to take in.  Consider sending someone back to the program later.  With additional experience, that person will understand the jargon, agencies, foundational requirements, and our industry more at that point.  That will free their minds to absorb more of the information.  It is like watching a soap opera for the first time.  You don't know the back stories, the personalities, or the developing plot lines.  But give it time and you'll get so much more out of watching each episode.  Or so I've been told.
3. If you send them, let them go.  I can't speak for other organizations, but I can speak for NAFCU.  Our Regulatory Compliance School is no piece of cake.  It is long and filled with information.  I'm always surprised to see so many folks who are still responsible for managing compliance issues back home while they are attending.  If your credit union sends a compliance officer to a certification program, please consider letting them go.  Literally.  Let the rest of the credit union understand that they are off-limits.  Learning is not easy, especially when Senor BlackBerry is buzzing every five minutes. 
4. Just one piece of the puzzle.  This is akin to the last point.  Sending a person through a certification program is great.  But if that person doesn't have the time and resources to do their job when they get home, they won't get the most out of their new skill-set.  Compliance is something one learns by getting their feet wet and hands dirty.  It takes time to read and digest.  It might take subscriptions to periodicals or manuals.  The more support and resources you can give your compliance officer, the better he or she will be at the job.