Collector - February 2018 - 20
Chief Compliance Officer, Magnet Solutions
Why Compliance: "I've worked my way up through
the company since I started here over 20 years ago as
a collector. In 2013, we made the business decision to
develop a compliance management system and create the
chief compliance officer role, and that was the beginning
of my career in compliance."
Keeps Me Up at Night: "Personal liability. You can
develop and design what you think is an effective management system for
compliance, but at the same time you still rely on other people to be part of that
system and that opens the door to some risk."
Lesson Learned: "How do you eat an elephant? One bite at a time. I have a lot of
big projects on my plate, and the best way to tackle them is to look at each one as
a group of smaller tasks."
Chief Compliance Officer, I.Q. Data International
Why Compliance: "I have been a licensed attorney for
almost 15 years and my favorite part of the job has been
helping clients enhance their compliance programs."
Keeps Me Up at Night: "The lack of regulatory certainty
at the federal level. It's a bit frustrating to advise a business
to make changes in anticipation of CFPB rulemaking and
then not have those rules come to fruition."
Lesson Learned: "You don't do your job by yourself. You absolutely have to have
the support and buy-in of business leadership that compliance is a priority."
Chief Compliance Officer, Allied Collection Services Inc.
Why Compliance: "I come from a military background
so I'm used to structure and rules. I think that's what
attracted me to it. But I definitely have to say that ACA
molded my career path thanks to the structure and
opportunities of their training programs."
Keeps Me Up at Night: "My biggest concern is what I
don't know that exists out there, or what I've missed, and
how that will impact our compliance program or elevate our risk threshold. Did
operations change something without telling me? Did a state regulator make a
change to a policy I don't know about? Who's changed what that I missed?"
Lesson Learned: "You have to look at a compliance program as a living,
breathing creature. You're not going to get it right on the first pass every time.
Not everyone is going to agree with you and thus the reason to ensure your role
remains proactive and objective. Don't be afraid to make mistakes-you will. The
key to being successful is diligence."
"When I walk the floor, I have the
best interest of all the staff within our
organizations," he said. "I listen objectively
to what they say and am encouraged
when they present scenarios or questions
regarding issues or concerns they may have or
experienced. This presents the opportunity for
me to identify process improvement areas. I
want them to know compliance is always here,
and that we're never going to stop changing."
THEY ARE STRONG
CCOs must be able to translate complex
requirements to employees at multiple levels
of the business in both written and verbal
communications. This starts at the top. The
CFPB expects to see board and management
oversight of the compliance officer, though
it doesn't stipulate exactly how often those
meetings should occur.
Albert Cadena, president and CEO of
USCB America, said he sets a standing weekly
meeting with his CCO to discuss what's
happening in the regulatory arena as well as
what projects are in motion internally.
"We're touching base on a regular basis,
even on the smallest things: changes he
wants to make in the IT infrastructure or
HR aspects," Cadena said. "I'm abreast of
At the collector level-and even the
consumer level-CCOs must be able to
convey compliance information in a way that's
easy to understand. Sometimes that entails
communicating the information in multiple
ways, such as through training sessions,
memos and informal conversations on the
Cadena noted that his CCO has to
communicate effectively not only with the
people inside his company, but also with
his clients. "I have our CCO communicate
with clients whenever a question arises
from them about how we handle certain
things," he said. "For instance, we have an
operation in Santa Rosa that was affected by
the California wildfires. We were closed for
a week and decided that we were not going
to communicate with patients in that area
because of the disaster. I had our compliance