We’re often asked whether the AffirmX Risk Intel Center Platform displaces compliance officers. To answer this question, I like to think about Batman and his gadgets. Bruce Wayne, although a very selfless and protective guy, wouldn’t be Batman and achieve many of his heroic feats without his gadgets: the utility belt, the Batmobile, the bat-shaped shuriken, etc. At the same time, while terribly useful, these tools could never replace Batman—but they do enhance his abilities.
It’s just the same with an institution’s compliance officer and a cloud-based solution, such as our AffirmX’s patented Risk Intel Center, which exists to enhance a compliance officer’s abilities.
The role of a compliance officer is multi-faceted. Therefore, before we dismiss the importance of the role of the compliance officer, let us carefully consider whether other solutions can accomplish the following roles in the absence of an on-site compliance officer (spoiler alert: they can’t):
- Monitoring new and changing regulations and determining whether they affect operations. This is a hefty task that requires patience and diligence to sort through the new regulations pumped out by the NCUA, FDIC, CFPB, etc. After digesting new rules, it is the compliance officer’s job to ascertain the effect they will have on the institution, based on its specific circumstances and needs, requiring an intimate knowledge of the institution.
- Keeping senior management and the Board apprised of regulatory changes. Oftentimes, that means regurgitating the regs into layman’s terms, as there may be Board members without extensive experience in regulatory matters.
- Ensuring that staff members are trained on any new or changing regulatory requirements. The officer must have sufficient understanding of the new requirements to train others who may or may not have equal financial experience. It takes a great deal of familiarity with the institution’s operating methods to know how and when to conduct these trainings.
- Ensuring that the regulatory requirements are implemented in a timely and accurate manner. Again, this requires familiarity with the institution’s operating methods, as well as personnel, in order to achieve successful implementation. The job doesn’t end there—after the compliance officer realizes implementation, he/she must carefully monitor the institution’s operations.
- Ensuring that new products and services are in compliance with regulatory requirements. This means that the officer must be vigilantly aware of product development and marketing/advertising.
- Addressing questions from the staff and the board in reference to regulatory matters. The compliance officer’s job doesn’t end after training staff and Board—his/her knowledge must be extensive enough to answer continual questions from all sides.
A Compliance Officer’s Utility Belt
AffirmX Risk Intel Center makes keeping up with regulatory change far more manageable for today’s compliance officer in several different ways. Take a look at the tools it brings to the compliance officer’s utility belt:
- Compliance review schedule: Rather than demand all of your compliance documents at once, our review schedule is set up to allocate items throughout the year, so they can be handled more manageably. That means that rather than demand everything at once, we work with you to do spread the reviews and reports throughout the year.
- Compliance review support: Our skilled team reviews your compliance materials off-site, thereby stretching your resources further than submitting you to frequent, intensive and burdensome on-site visits.
- Compliance Reporter: This publication, written by our subject matter experts, provides overviews to important regulatory proposals or changes. The Compliance Reporter can be found in our Risk Intel Center platform. Because these articles are an overview of the critical points or regulatory proposals or changes, they’re short enough for the Board to digest.
- Global risk rating: In the Risk Intel platform, we assign each area of compliance (BSA, Operations, etc.) a “global risk rating,” meaning a certain level of risk manifested by the industry itself that affects all institutions. Because we monitor general risk trends in the industry, your institution’s risk score may rise or lower accordingly, keeping it as relevant and accurate as possible. The other rating factored into your overall risk score is the one you receive for each compliance review (mentioned in #1 and #2).
- Risk Management Manual:This manual, exclusively for AffirmX clients, serves as a guide to current regulatory requirements. Each of our clients receives their own customized edition of the Risk Management Manual ordered by the regulations most relevant to their institution. This manual contains detailed guidance on essentially every compliance aspect imaginable—from Privacy to Truth in Lending.
- Risk Inbox: This is a website dedicated to the day-to-day compliance, agency, and industry news and trends discovered by our analysts through their research of important industry sites. This website is free to all users and can be accessed at RiskInboX.com.
Unless your outsourced solution is capable of addressing all of these areas (in which case, congratulations!), you will still need someone within the organization to bear responsibility for those capabilities not encompassed by the outsourced solution. For example, the most common limitation of outsourced solutions is in implementation. Off-site systems simply cannot oversee implementation like the compliance officer can. This means you will need to have someone in your organization who is responsible for implementing regulatory changes, for addressing any compliance violations noted during examinations and audits, and to act as a liaison with your examiners and auditors during their visits.
In particular, the AffirmX compliance solution is not intended to replace your existing compliance officer, but rather to make him or her more effective by unburdening him or her from the time-consuming task of monitoring operations. We do this through our cloud-based, ongoing compliance reviews and by providing timely and informative compliance reference tools, such as our online compliance manual and periodic regulatory updates. We hope to enable your compliance officer to do more with less.
In short, while Batman’s tools could never replace Batman, Batman is far more effective with them, just as today’s compliance officer is made far more effective with the enhancements offered by a cloud-based solution, such as the AffirmX Risk Intel Center.