Culture, Training and Compliance – Part 1

Thomas Fox

Compliance Evangelist

I recently had the opportunity to visit with, Tina Rampino, Associate Managing Director at K2 Integrity. Tina has one of the top phrases I have heard around compliance training. It is ‘espresso shots’ of training to help facilitate attainable training demands. We also discussed the operationalization of compliance training.

Espresso Shots of Training

Rampino advised on what she called “an espresso shot” of compliance training which can be both shorter and more concise, but drills down to specific risks relevant to an institution. She went on to relate that she has been involved in creating solutions that can deliver shorter and more tailored training which will result in increased relevance to the employee and have a lighter burden of training hours. Rampino said, “The concept of espresso shot training can assist employees to better manage their workload while keeping up with important issues relevant to their roles. For example, institutions should think creatively on delivery and modality of training content. Not only in an e-learning format: something engaging, cartoons, videos, interactive virtual training.”

I think that every compliance professional strives to find the right balance between training on general awareness topics and shorter, more relevant and practical training opportunities.  Unfortunately, compliance training is viewed as a “check the box” activity or worse, something that is dreaded and is usually ineffective. Rampino suggested compliance training incorporates real life scenarios, case studies or simulations to give employees an opportunity to learn in a sand box environment and to practice the skills that they are being taught.

Some of her suggestions include keeping your compliance training segments concise as “shorter, bite-size learning is a trend in training programs.” This means that instead of offering half-day and full-day sessions, break programs into shorter segments of 20 minutes or less, which are easier for participants to absorb – and schedule. Another example is that short cartoons or animated videos can be excellent quarterly reminders. Done properly, they do not feel like an assessment or certainly not a ‘check-the-box’ exercise. The bottom line is that with all training most employees must undergo now and even more so in the continued time of the Covid-19 Delta Variant, espresso shots give people back a lot of time.

Operational Aspects of Training

Next we turned to key operational aspects of training, including budget, delivery and more. We began with a discussion of one of the most critical issues around compliance training, but one I believe does not get nearly enough discussion in the compliance community, that being the issue of budgeting. During times of economic stress compliance training budgets are often tightened. Rampino believes this approach needs to be avoided. The reason is straight forward, “investing in training and professional development for employees can save money in the long-run, both operationally and when it comes to regulatory requirements. An institution’s greatest asset is their employees and especially when you’re entrusting them to protect your institution from risk.”

This means that if you are providing employees with ongoing training to assist them to continuously refine their knowledge and skills; it will also keep them engaged and incentivized to take compliance more seriously. Moreover, as Rampino noted, “developing and retaining employees is beneficial to financial institutions in the long-run and demonstrates sustainability within the compliance program.” Instead of cutting back on training budgets in general, institutions should assess the training needs as they align with the greatest risk and find ways to deliver the most targeted and relevant training across the enterprise. Rampino advocates several different styles of compliance training. These include, having a “balance of online/in-person training; including independent or self-guided training; as well as hands on training with an instructor.”

We then turned to the concept of compliance training as a cost saving exercise. Rampino reiterated that “skilled and experienced employees are a critical part of a sustainable and effective program. While training may not be the highest priority, when a compliance officer is looking at their list of money spend for year; training is critical in proactively reducing compliance errors and risk.” Additionally, employees who receive timely and engaging training often feel that an institution is investing in them and their professional growth, which can lead to less turnover. Rampino concluded, it demonstrates “an institutions appreciates the importance of career pathing and skills development. It is not just for the regulators, but for health and wellbeing of an institution.”

Think about that for a minute; training should also assess the skills needed for each role and provide a career path for employees. Employees want to understand they are growing professionally. Management desires its employees to “understand that people they have in those roles have the right training and are experienced.” Rampino concluded that this means “training is a resource bigger than what it looks like on paper. That’s why budget and resources for training is so important. Training is a way to mitigate risk within the institution—both in terms of real risks that come in the door every day and demonstrating a sustainable way to do so.”

We concluded with Rampino’s thoughts on regulatory expectations around compliance training.  She believes, “Regulators are more interested than ever in seeing that an institution is investing in a sustainable, scalable, and dynamic training program. They want to know that an institution understands their risks and that it demonstrates that with the training that is provided to their employees. Regulators are expecting more targeted and role-based training offerings and that the content is evolving as the risks evolve.”

In the vein of my mantra Document, Document, and Document, Rampino also noted that regulators are “more focused than ever on how the financial institution is assessing compliance skills needed for critical roles and demonstrating that their employees meet the skill requirements for the roles that they are in.” This means a potential audit on areas as wide-ranging as “how an institution provides career pathing, professional development, and cross-training opportunities for their employees.” But this is much more than a myopic view of compliance training only as it “ensures sustainability of the program but also allows for flexibility as financial institutions adapt to the changes and may face organizational or structural changes, as many do due to a host of issues ranging from regulatory remediation to right-sizing.”

Training and its attendant skills development have become critical in empowering employees to move into new roles as needs arise and offers growth opportunity which is valuable beyond measure in the current environment that institutions are operating in. She concluded by stating that regulators “want to know that compliance employees not only understand their institutions internal risk, policies/procedures, and escalation processes but also that they are staying current with industry best practices and emerging risks.”

K2 Integrity has developed an online training platform and resource center, Dedicated Online Financial Integrity Network (DOLFIN), to help clients with their training requirements and provide more diverse options for training content and modalities. Find out more about DOLFIN here. For more information on K2 Integrity click here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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