What makes one firm – and the various professionals who represent it – live and breathe by the book, while others are a bunch of scofflaws? I can tell you this for sure: there is no magic potion that you can buy to embed a culture of compliance in an organization.
As cliché as it may sound, I honestly believe this starts at the top. Try as you might, if the leadership of the firm truly believes it’s OK to get a “C” in compliance (or worse!), you’re going to have a hard time moving the needle. This is where, as compliance officers, we need to dig deep into ourselves and find a salesman.
Tone at the top is critical because everything you need to do depends on their buy-in in some form or another. Need more resources to effectively implement your compliance program? Need time on the calendar for all associates to participate in training? Assistance in responding to a regulatory inquiry or examination? Recommending the firm terminate the employment of your number one salesperson because of repeated compliance breaches? For each of these, and many other challenges, you are going to need management’s buy-in.
Whether you are a large firm staffed with hundreds of compliance professionals or a dual-hatted CCO in a small shop, compliance is infinitely more effective when the head(s) of the firm are setting a good example. If the bosses take compliance seriously, day in and day out, the other employees are far more likely to take it seriously. If the bosses think it’s OK to complete attestations past the due date, don’t care if new account paperwork is incomplete, regularly suggest aggressive or inappropriate marketing tactics, it’s much more likely that others will pick up these habits. And if management does not hold employees accountable for their actions, or support you in addressing compliance breaches, recidivism will run rampant. New hires will learn bad habits, and if weeding out a bad actor isn’t important, each person hired might bring more issues that pollute the firm’s environment further.
As the steward of compliance in your organization, keep your eyes and ears open, motivate management to lead through their actions and words, and no matter what, be approachable and adaptable. Truly partner with them to help the firm achieve its goals efficiently and compliantly. That just might be the magic potion we’re all looking for.
To read the full chapter Compliance Culture in a Bottle, download The CCO’s Playbook.
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