Emerging from the discussions at COMPLY were five themes that are defining the compliance industry's collective strategic focus, shaping policy and propelling innovation. Hear from industry experts below including Fifth Third Bank, CFPB, Attorney General Office of PA, New York Life, FTC, Shareablee, State of NJ Division of Consumer Affairs, Barclays, Mastercard, Attorney General Office of NY, Ascent RegTech and PerformLine as they share critical insights that every compliance professional should know.
1 | Compliance Management Requires a First Line of Defense Strategy
In response to today’s aggressive regulatory environment, having an active first line of defense strategy is no longer optional. Compliance management demands day-to-day attention to deliver on strategic goals. Industry experts are embracing this idea by developing an approach that proactively addresses compliance and risk issues with consumers every day.
“Don’t think about compliance as a second line function or org structure, but think about compliance as an integral part of delivering your strategy.”
- Marybeth McManus, SVP of Business Process Controls, Fifth Third Bank
“We [CFPB] regarded sound compliance management as the first line of consumer protection, and our regulatory efforts secondary to that process. It has always been true that the success of a company begins and ends with how it treats its customers.”
- Richard Cordray, Founding & Former Director of The CFPB
“Anything that comes in from a regulatory or law enforcement agency, triage those complaints and see what they’re complaining about. Be proactive with what you’re seeing.”
- Sam Mirarchi, Senior Deputy Attorney General, PA Bureau of Consumer Protection
2 | Social Media Compliance as Part of Risk Management
With over 3.4 billion active users across the globe, social media is a massive platform for marketers, and in turn, has become a big focus for regulators. As regulators continue to focus on social media, it’s important now more than ever for companies to focus on including social media compliance in their first line of defense strategy.
"We realized that we had to provide our employees with guidance because they are accidental influencers."
- Dipayan Gupta, CVP Social Media Brand Marketing, New York Life
“Maintaining control of your marketing content and brand guidelines is critical - as your reach goes up, so does your risk.”
- Tony Paterno, SVP of Operations, PerformLine
“If you were to add up all of the social media engagement across platforms, including everything published by big social publishers and brands, and compared that to influencer engagement, influencer engagement would be about three quarters of that activity. It’s a really fast growing and important space.”
- Tania Yuki, Founder & CEO, Shareablee
3 | Bilateral Solving for Consumer Complaints
Organizations need to solve not just for the complaint at hand, but solve for the problem causing the complaint. This is a nuance shift in thinking as most companies tend to solve for the complaint, putting the real issue on the back burner. Industry experts advise bilateral solving as it will not only help reduce risk, but help create a good working relationship with regulators. A win-win.
“By the time someone makes a complaint to us, it’s because they’ve been running into a brick wall with your company.”
- Paul Rodriguez, Director of The Division of Consumer Affairs, State of New Jersey
“[It’s all about] really looking at the root cause of the complaint that you’re receiving and making sure you’re fixing that root cause, as opposed to fixing the immediate problem in front of you and that immediate complaint.”
- Chris D’Angelo, Chief Deputy Attorney General for Economic Justice, New York Attorney General's Office
“Banks should be more like wifi. You’re always there, you’re present, enough bandwidth, secure and people will take you for granted all the time, until the wifi goes down and everyone will hear about it.”
- Aparna Menon, VP of Digital Marketing, Barclays
4 | Consumer Focused Innovation & Technology
Regulators, global brands and technology companies are unanimously in pursuit of better serving and protecting their consumer’s needs. Innovation and technology go hand-in-hand as organizations create products to support consumers needs with a focus on consumer protection.
“We depend on innovation and competition to derive those positive dynamics that consumers can experience so that they can have a holistic experience of consumer protection. Not just enforcement and rules preventing the downside, but competition and innovation driving the upside and providing them the opportunity to access better products.”
- Paul Watkins, Assistant Director Office of Innovation, CFPB
“Consumers want speed and convenience these days. And in order to do that, we need to actually use the technology and create easy, frictionless ways to access credit.”
-Tina Woo, Senior Managing Counsel of Regulatory Affairs, Mastercard
“Don't be a hammer looking for nails, find the nail first, figure out if it's a nail or a screw, then build the tool that you need to solve the problem. It sounds simple, but it's a difficult thing to hammer home (pun intended).”
- Brian Clark, Founder & CEO, Ascent RegTech
5 | Collaboration & Partnerships
The focus on innovating to solve for consumer needs has lead to an explosion of new collaborations and partnerships in the industry. Global consultancies are partnering with RegTechs (regulatory technologies) to marry their advisory expertise with technology. Even the regulators are making a conscious effort to work with and collaborate with each other.
“We have working groups focused on specific areas or practices so that we’re in the loop on each other’s work … the idea is to make sure that we understand where each other is, that we’re not being burdensome and that we’re using resources efficiently.”
- Sandy Brown, Assistant Director, Division of Financial Practices, FTC
“Game-changing alliances are forming everywhere we look these days. And not only between departments like content controls and marketing, or risk and sales, but also between different companies and organizations. The spirit of collaboration is alive and well.”
- Alex Baydin, Founder & CEO, PerformLine
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