Compliance Management System (CMS) Check-up
by: Rob Ellis
When was the last time you did a thorough review of your CMS? How effective is your program in preventing issues, or is it weighted more to detecting problems after they’ve occurred? Are you spending too much time and resources doing monitoring and testing instead of strengthening your first line of defense with an emphasis on automated processes and procedures provided by today’s technological resources? Designing a program that focuses on this proactive approach makes the traditional 2nd and 3rd lines of defense monitoring process more of an assurance review step. The monitoring and file review aspects of a CMS should just be a validation process proving what you put in place up front is working as designed. Today's technologies can help make Compliance much more simplified and efficient.
In the past, processing loans was heavily weighted with manual intervention requiring humans to fill out the content of disclosures and get those disclosures provided to customers in a timely manner. We know that process was fraught with errors requiring robust systems of monitoring and audit to try and capture and correct those errors. However, in today's world there are many software and technology solutions that automate so many compliance-required processes that leveraging these resources can lessen the weight financial institutions previously needed to put on audit and monitoring.
Many financial institutions have taken full use of these advancements in technology and have evolved their products and operating models to be more effective and efficient. However, their CMS models have not grown in step with these changing business platforms.
SCA’s team of compliance experts assist our clients with successfully managing their compliance risk and can tailor an engagement to meet your needs.
For a free consultation to discuss specific regulatory requirements, to review your CMS program or to perform a targeted assessment, contact Bill Dolan, Director at (617) 694-2617 or visit our website at: www.scapartnering.com to learn more about SCA’s consulting services.
