Compliance Program Assessment and Direction
Institutions may require a comprehensive assessment in order to understand what is needed to create a formal compliance program. This differs from an assessment of compliance with a particular regulation, as it examines the existing organizational structures and operations in place to support a culture of compliance and what else is needed for success.
Once we have completed the assessment, you may want us to assist you with the development and implementation of a plan in support of a formal compliance program. We can identify all institutional stakeholders and, using industry standard forms and procedures, lead those stakeholders through the program development process.
Development of a formal compliance program is of potentially enormous benefit. One benefit is that it can significantly mitigate fines, penalties and even jail time for trustees and administrators if someone in the organization engages in criminal activity, per the Federal Sentencing Guidelines. It can also help mitigate some very specific risks, such as claims against administrators for retaliation, since an anti-retaliation plan is an essential part of a formal compliance program.
Smaller institutions are not necessarily expected, under the Federal Sentencing Guidelines, to have a full-time person managing compliance. The benefit of using our services is that we can help your organization set up the necessary internal structures (e.g., committees, policies, procedures) to achieve a high level of competence with existing staff for years to come.