You did it! Your organization has developed robust policies and procedures for all levels of staff, which will minimize your compliance risk to the greatest extent possible. Time to sit back, enjoy the fruits of your labor and be compliant. Not so fast! Policy and procedural documentation, while of utmost importance in creating a compliance-focused organization, mean very little if your staff is not appropriately trained to execute the policies.
In our last article, we discussed the merits of training at the dealership level. Today, we’re going to focus on the merits of regulatory compliance training at the organizational level. When we look at the pillars of an effective compliance management system (CMS), training is the glue that holds your entire program together. Take Brandon from your Customer Service department, for example. He’s a great worker. He always wants to do the right thing for the customer and the organization. Brandon (along with the rest of the organization) recently received an email from your compliance team highlighting the new Unfair, deceptive, or abusive acts and practices (UDAAP) policy that was just put into place. He takes it to heart and understands that deception and abuse have no place within your organization. However, without training on the policy, is Brandon really equipped to identify said deceptive or abusive acts? Over the course of his daily job duties, he believes some elements may be considered abusive or deceptive, but he’s not quite sure. What should he do now? Does he know where—or to whom—he should voice, clarify, or report his concerns?
Complaints Management is another area that may seem self-explanatory. We all know how to identify when someone is complaining, right? Well, maybe not. Regulators generally look for “buzzwords” as an indication of a customer complaint. Frequently, a consumer will neglect to mention that he or she is formally complaining about an experience they’ve had with your organization. Thus, appropriate training on the policy enables your staff to recognize these “buzzwords” in order to successfully identify complaints. Here’s a few examples of complaints that may not be immediately evident:
- “I’m going to post about this on social media.”
- “I’m worried my account information was shared with a stranger.”
- “It’s not fair to expect me to pay a late fee in this circumstance.”
The list can go on, and while there may not be a definitive listing of all the possible complaint phrases or words a customer will use, training employees in how to identify a complaint will assist them in capturing and escalating the complaint as needed.
The missing link in many training programs isn’t necessarily the lack of content presented to your staff, it’s answering the age-old question, “Why should I care?” We’ve probably all attended regulatory compliance trainings where we leave the session asking ourselves, “How does this apply to my day-to-day job responsibilities?” Making training relevant to the intended audience is therefore key: Training for your Title Services department should be quite different than the training for your Collections teams. When employees truly understand how errors or oversights within their daily job responsibilities can impact the organization as a whole, the point hits much closer to home. Moreover, the way you convey the message, including providing real-world examples, allows employees to link the content of the training to their individual job titles. Employees should thoroughly grasp the potential costs of non-compliance for the organization and the role they play in sustaining an organization that is dedicated to compliance.
Clearly, the most important goal of compliance training is to keep your organization out of regulatory crosshairs and your customers happy, which takes us to the next critical point: Regulations change often, perhaps due to the political climate or situations like the current pandemic. Training programs require review on a frequent basis to ensure they’re in alignment with regulatory expectations, but compliance training isn’t a “one and done” activity where training materials are dispersed to employees on an annual basis. Instead, programs require appropriate review and alignment to regulations in order to remain relevant to and compliant with current-day regulations.
There is certainly a cost to implementing and maintaining up-to-date comprehensive compliance training, but it adds significant value to your business in the process, as the reputation your organization holds is directly impacted by your compliance activities. Elements like legal complications, consent orders and matters requiring attention (MRAs) often have a cost that far exceeds the cost of compliance: Regulatory or legal issues create a negative perception of your organization, but being perceived as a compliance-focused organization has a positive impact that attracts (and retains) clientele.
While compliance training may be seen as a “check the box”-type activity by some, in reality it enables employees to become knowledgeable about the regulatory environment that their organization is subject to and the role they play in driving this culture of compliance home. Author Norton Juster summarizes it perfectly: “It’s not just learning that’s important. It’s learning what to do with what you learn and learning why you learn things that matters.”
