Day: September 17, 2021

Welcome to this special podcast series, Integrity Matters: Culture, Training and Compliance, sponsored by K2 Integrity. This week I visit with Koby Bambilia, Managing Director, and Tina Rampino, Associate Managing Director. Over the series we have broken down corporate culture, compliance training and communications. Topics included breaking down the big picture on culture, espresso shots of training, skills development and regulatory changes, tailored and risked based training and operational aspects of training. In this concluding Part 5, I am joined again by Tina Rampino who reviews 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.