Come Ply with Me
I’ve heard it countless times as I’ve
flown a lot on airlines both domestically
and internationally. In fact, I recently
even rode a flying dragon! OK, it actually was an airplane, but the airline is
called DragonAir, so technically it was.
Well, anyway, I was on their Hong Kong
to Bangalore flight, and even on The
Other Side of the world, even on a flying dragon, the regulatory briefings are
pretty much the same.
That got me thinking, maybe there is
something we banking compliance pro-
fessionals can learn from our airborne
cousins. Maybe just giving customers
a ream of paper (AKA disclosures) is
not really very effective. Wouldn’t it be
much more “fair” and “reasonable” to
give in-branch demonstrations and
announcements as well? You know,
ask them to put down all of their
reading material and pay close at-
tention to the financial attendants
standing by the teller line as they
present some very important messages.
Here’s how it might go:
“Lendees and depositors, welcome to
Consumer BankAir, with a transactional
destination of Fairbanks (naturally). May
we please have your attention as we disclose the safety and soundness features of
this Branch #747.
First, please note that the branch man-
AIR TRAVEL IS A GREAT EXAMPLE OF COMPLIANCE in another highly regulated industry, and whether you’re a frequent flyer or not, most everyone has been on a plane and experienced the preflight safety briefing.
mortgage life-rafts will inflate and can be
used to “short sail” yourself to safety.
Finally, this is a strict “no-structuring”
bank and it is a federal offense to dismantle or avoid no-structuring detectors.
Should you notice anyone doing so, or
anything else suspicious, please alert one of
the financial attendants immediately. Our
motto is: “Better Safe than SAR-y.”
I have to admit, there was one really unusual thing about the DragonAir
flight. After drinking some beverages and
then a very long stretch of having to stay
seated due to turbulence over the Bay
of Bengal, it became extremely urgent
for me to get to the lavatory as soon as
the seatbelt sign went off (see, I’m a true
compliance type; I stayed in my seat as
instructed). However, it gave me a moment of pause when I finally got into the
lavatory. As soon as I shut the door I saw
there was a window directly above the
toilet! (Honest! I even took the picture
at left.)
I’m thinking this must be some kind
of Regulation P violation, but I really
had to go so there was no time to mea-
sure the level of risk, much less try to
control the exposure. I guess you could
say I became an “emergency
flasher.” ■
ager has illuminated the “Fasten CD-belt”
sign. When this sign is illuminated you
are required by federal regulation to keep
your funds securely deposited in your CD
account for at least the first seven days. At
that time the manager will turn off the
Fasten CD-belt sign and you will be able
to move your funds freely around your
accounts.
As the financial attendants are now
pointing out, there are two sets of disclosure postings in this branch, one near the
front door where you entered, and the
other by the teller line. Please look around
as the nearest HMDA Notice may be behind you.
In case of a sudden drop in housing
prices resulting in under-water lending,
ABOUT THE AUTHOR
STU LEHR, CRCM, is an Industry Principal for Finacle, at Infosys Technologies Limited. For the 20-plus years prior to this he
developed and lead compliance programs
for a number of banks and an on-line
payments provider. In addition, he has
served on the ABA Compliance Executive
Committee, the ABA Regulatory Compliance
Conference Planning Committee, and still
serves on the faculty for the ABA
Compliance Schools. He earned the 2002
ABA Distinguished Service Award and is a
Certified Regulatory Compliance Manager
through the ABA Institute of Certified
Bankers. Reach him at stu.lehr@gmail.com.
