Outsourcing Compliance-A Frank Discussion

VCM is a company that specializes in outsourcing compliance.  We understand that this concept can, quite frankly be confusing and in the case of the incumbent compliance officer, frightening!    We would like the opportunity to address some of the misconceptions and concerns associated with this field. 

 

1.       What is outsourcing? 

a.       The truth is that outsourcing is different things to different companies.  In our view outsourcing means reducing stress!  Our firm is designed to support banks existing compliance function.  Many of our banks consider themselves “business banks” that do very limited consumer lending.  As a result, the compliance program gets little attention and few resources.   That is where VCM comes in.  We have a staff of compliance experts who have the training, experience and knowledge of the laws and regulations that apply to your bank.   We work directly with lending and operations staff at our banks to make sure their BSA and compliance programs are up to date.

2.       Won’t VCM help the Bank get rid of my job?

a.       We do exactly the opposite.  Our goal is to use our resources to augment the resources at our banks.  We take pride in making our clients CMP and BSA programs strong.

3.       What if we only need occasional help with compliance issues?

a.       In our opinion, it is extremely rare that only occasional help is needed.  The issues that lead to our clients contacting us almost always are part of a larger concern with at least one portion of the overall compliance program.  We find that the more inexpensive and most efficient route is to allow for a complete outsourcing program to review all areas of the compliance program and to implement changes to strengthen compliance. 

4.       Wouldn’t it be cheaper to hire a compliance officer?

a.       Not at all!  Really good compliance officers are really hard to come by!  To be an excellent compliance officer, one most have hours and hours of experience, training and certifications.  In addition, with the myriad changes in laws and regulations, a good compliance officer must receive hours of training on an annual basis.  With outsourcing, the Bank can leverage the skill and experience of the incumbent officer with the additional training and experience that we provide.  

5.       Specifically what comes with the VCM outsourcing package?   

·        Risk Assessment: The way that we support our clients is multifaceted.  We provide an annual risk assessment that is designed to identify overall risk at the Bank and the manner in which compliance risk is a factor in overall risk.   We the design our approach to fit the unique needs of our client.  

·        Policies and Procedures:  we review all relevant policies and procedures to make sure they are up to date, comprehensive and relevant to overall risk and level of operations at the Bank.  

·        Forms and Checklists:  using the experience of staff, we develop, as necessary forms and checklist that assist bank staff in maintaining compliance.  

·        Ongoing Assistance:  Through of ‘hotline” we are available to answer questions as they arise on an ongoing basis.    All questions receive a 48 turnaround for answers.  

·        Quarterly Quality Control Review: We conduct transaction testing of a sample of accounts to determine the level of compliance with applicable regulations and Bank policies and procedures   

6.       Once we have a good compliance program in place, why would we need to keep VCM?  

a.       A strong compliance program relies on several factors.  These factors are known as the pillars.  The components of a strong program include

                                                               i.      Policies and procedures;

                                                             ii.      Training;

                                                            iii.      Management Information;

                                                           iv.      Independent audit;

VCM assist with each of these.  We review the policies that are in place and make sure that they are up to date and are approved by the Board on a timely annual basis.  We do the same with the procedures that have been designed to implement the policies.  We provide training on an on-going basis.  Through our quarterly quality control checks, we provide management with information on the level of compliance with policies and procedures. 

7.       How can I find out more? 

a.       This is the easiest question of all!  Please feel free to contact us at www.VCM4you.com  or at 510-583-0124.