Collector - October 2020 - 21

of development. And most importantly,
compliance employees have been defined
as "non-revenue generating" employees,
and given the formal or informal directive
to do the least amount possible to not
negatively affect the bottom line.
This is part of why compliance
departments are often considered "The
Department of No." When compliance is
involved at earlier stages, helping design
and develop new programs, processes,
procedures and functions, it transforms
compliance into "The Department of
Know." Giving compliance a seat at the
table in the beginning stages means
innovations are implemented more
quickly because they are built on a
compliant and ethical foundation from
the outset, rather than having to revisit
projects because compliance wasn't
consulted during the planning stages.
It's time for agencies to take the next
step in the evolution of their compliance
departments and CMS. Empower your
compliance department to use the data,
systems and processes it has established
to proactively and positively influence
innovation and production.
Compliance departments can (and
should) be independent from a reporting
perspective, while still being intimately
involved in strategic, operational, financial,
governance and other decision-making
aspects of the organization.
Agencies can use established compliance
controls and quality assurance processes
to test new technology, and measure and
monitor revenue-generating activities
to increase efficiencies and consumer
engagement.

EXPANDING YOUR VISION
The first step in transforming your CMS
is to expand your line of sight into each
area of the company. Many agencies limit
their CMS to four main areas: internal
compliance, external compliance, data
privacy and vendor management.
These four areas are certainly robust
and include a line of sight into many
areas of a company. However, they tend

COLLECTOR 10.20

"Use your CMS to monitor consumer
engagement and revenue-generating
processes to increase efficiency, reduce
costs and boost revenue."

to be focused, rightly so, on consumerfacing processes. For an agency's CMS to
achieve its full potential, it needs to include
processes or departments that are nonconsumer facing, such as the operational,
strategic and financial areas of a company.
At a minimum, compliance and quality
assurance should interact with:
1.	Operational areas, including supply
chain, people, physical assets,
information technology, hazards, and
sales and marketing;
2.	Strategic areas, including
organizational governance, corporate
vision, codes of ethics, planning
and resource allocation, market
dynamics, incentives, and mergers
and acquisitions; and
3.	Financial areas, including accounting
and reporting, capital structure,
market dynamics and tax structure.

APPLYING CONTROLS
Once your controls and quality assurance
processes are established, apply them
to new areas in the company. The most
common quality assurance controls
are separated out into two categories:
systemic controls and manual controls.
Systemic controls can be implemented
through technology and software
systems. One common example of a
systemic control is exception reporting,
which is generated when an exception
to a process occurs. Compliance or
quality assurance employees can
review the reports to determine why an
exception has occurred and make any
necessary corrections to the process. The
compliance department then reports

the exception to higher management as
necessary.
These reports are invaluable in a CMS
to ensure full compliance with state and
federal regulations as well as internal
policies and procedures. They also add
value to your compliance department
by increasing efficiencies with employee
resources. An agency can use these
systemic reports to increase efficiencies in
other areas and departments that are not
currently under compliance.
For processes that cannot be monitored
by systemic controls, there are manual
controls. One of the most common
examples of a manual control is called
"maker-checker." This is a type of control
where one employee does the process
or procedure (the maker) and another
employee (the checker) checks the
compliance of the work.
Just because these are not as efficient
as systemic controls does not mean they
will not add value or efficiency to other
departments or processes. Agencies
often use maker-checker control reports
that can be viewed by quality assurance
employees within the compliance
department or by management. For
example, if an agency adds a makerchecker control in the accounting
department, the checker can be within
the accounting department generating
a report for compliance and quality
assurance, or the checker can be a
compliance employee generating a report
for upper management, depending on
the importance of the process.
The value of these controls is not unlike
the value of systemic controls in that they

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Collector - October 2020

Table of Contents for the Digital Edition of Collector - October 2020

Collector - October 2020 - Cover1
Collector - October 2020 - Cover2
Collector - October 2020 - 1
Collector - October 2020 - 2
Collector - October 2020 - 3
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