Consultant Spotlight Series: Meet Robert Ellis
Interview conducted by Donna Thaxter – Training, Coaching, and Professional Development Consultant
Robert Ellis is a Senior Compliance Consultant with over 30 years of experience within the banking and lending industries. Before joining SCA, Rob worked for the FDIC/DOB as a regulator/examiner in New England. He was a Compliance Director for financial institutions throughout New England and Florida. He is a subject matter expert in Compliance, specializing in developing Compliance Management Systems (CMS) and conducting risk assessments in Fair Lending and beyond.
Donna: Good morning, Rob; it’s great to have you as the subject for this week’s Consultant Spotlight. So, we’ll just jump right in. There’s a lot going on in the regulatory compliance arena right now, and we could take this interview in many directions. What do you think Compliance Officers and business leaders in community institutions should be thinking about today?
Rob: Well, the pace of regulatory change and scrutiny is as intense now as ever. We’ve all seen recent headlines about multi-million-dollar fines and other enforcement actions happening. And then, there’s COVID, which triggered a rapid change in the form of the expansion of technology in all bank processes. Everything is done electronically today, and many compliance officers feel left behind. So, my short answer to your question is that compliance managers need to gain a realistic and current view of their institution’s vulnerabilities and risks and then create a targeted plan to address those risks.
This starts with taking an unfiltered look at your Compliance Management System (CMS). Kicking your CMS tires and conducting an assessment that challenges key aspects of your CMS program. To do this right, you need a certain degree of independence, and while it’s not impossible to do this internally, it can be extremely challenging to get it right.
Donna: So, what options do Compliance Officers have to get their CMS Assessment right?
Rob: Having worked in a number of banks as a Compliance Director, I understand the challenges Compliance Officers face when evaluating or strengthening their CMS Program. Many Compliance Officers today support multiple areas of their institution and have to become experts in each area. Compliance Officers essentially have two main options:
Outsource your CMS Assessments. This approach inherently brings independence to the process. It allows Compliance Officers to gain a broader perspective, including regulatory expectations and trends affecting CMS scope, process, and appropriate risk assessment structures.
or,
Build and Maintain your CMS Assessment Program Internally: This approach naturally comes with more challenges related to independence and objectivity. It can be done but requires significant time investments on the process side and in ensuring your CMS assessment stays current with organizational and regulatory changes.
Each institution has to determine which approach works best for them and consider which alternative will give them peace of mind and no major surprises in their next exam.
Donna: Rob, thank you for sharing your thoughts on this important subject of compliance management system assessment. This is all excellent information, and it raises some important considerations for Compliance Officers in today’s business and regulatory environment.
On a lighter note, would you mind sharing what you enjoy doing when you’re not helping clients with their compliance challenges?
Rob: Sure [laughs]. Ok, so this is not a well-known fact about me, but I’m a bit of a Rock Star in the local Karaoke community here.
Donna: Wow, that’s a really fun fact about you. Do you have a specialty?
Rob: Yes I do. Country is my main genre, but when I’m feeling really gutsy, I might break out some Elvis tunes. It’s a great way to decompress on a Friday evening, and I’ve met a lot of great people in the process.
Donna: Rob, big thanks for ending on such a high and fun note (no pun intended). And to our readers, be sure to join us next month when we bring Rob back to cover some more best practices for Compliance Managers, whether you outsource your CMS Assessment System or Build it from within.
To learn more about how Rob can assist you with enhancing your CMS Program or a CMS Assessment process, contact our Director, Bill Dolan. You can reach Bill via email (WDolan@scapartnering.com) or phone (617-694-2617).
