THE OTHER SIDE | BY STU LEHR
This way, from just a few selfies, you too can
have your own personal bobble-head created to
similarly use as an ”award/public shaming” at
your bank. Think how fun that will be! Presenting a three-dimensional, bouncy reminder to
recipients of how they, as a business group or
perhaps even a support group (I’m looking at
you IT programmers), have unfortunately gone
“above and beyond” to bobble the response to,
adherence with, or reasonable interpretation of
a regulatory requirement. Even for those who
don’t win, it’s a dishonor just to be nominated.
There will be different categories of course.
The biggest Bobble acknowledgement is
“America’s Top Bobble” which goes to the bank
paying the largest penalties or with the most
negative news stories for the year (some immediate leading contenders come to mind).
Next is the “Bobble-U” (typically awarded to
Marketing) for the most outstandingly egregious UDAAP violation of the year. (Some
banks will win both of these top two awards—
an occurrence we call “the Bobbly Twins.”)
However, there are other significant categories,
such as “Bobble-IT” for exceptional achieve-
ment in technology blunders, “Bobble-C” for
an individual bad performance in the lead “C”
role of CEO, COO, CIO, CCO or any of the
other “C’s” (but not See’s Candies—we love
them). Just to be fair, we also have a regulator
category called the “Bobble-Y?” This is given
to an agency when we want to know why on
something. For example, why does an imple-
mentation deadline precede reasonable lead
times? Special negative recognition will be
given when answers to process questions and
other specific direction are still pending but
deadlines are not extended. TRID was the
previous (and undisputed) title winner.
Instead of “black tie,” it is more of a black
eye affair. Recipients will be “called on the
(red) carpet” where they will be required to
be dressed appropriately. For men (the vast
majority of the “winners”) they will be need to
be attired in top hat and tails (with their tails
“tuxed” between their legs). Since they rarely
do it on their own accord, they will likely need
to hire an “apology-stylist” to help them “make
up” to the Compliance team. You can act as
your own Emcee (Master of Cruelties) for this
night of glamorous retribution. And just imag-
ine their heartless acceptance speeches:
“I’d like to blame everyone involved in this
product release, but especially the Marketing
Department. Without your scheming none of
this would have been possible. I also have to ac-
knowledge executive management, who despite
your clueless vision gave us a one-dimensional
bonus structure based solely on revenue gen-
eration and that was all the encouragement we
needed. Thank you IT for pushing the release
through without all that ‘testing’ nonsense. Of
course, there were challenges with those pesky
regulatory requirements the Compliance team
insisted were actually “rules” and not sugges-
tions. Frankly, we didn’t think the Compliance
people were being ‘fair or reasonable’ to us by
getting in the way of our very lucrative roll-out.”
Some will say it’s not nice to do this kind of
negative acknowledgment. In fact, my mother
always said, “If you don’t have anything nice to
say, don’t say anything at all.” On the other hand,
my feeling is–it’s only fair to give discredit where
discredit is due.
ABOUT THE AUTHOR
STU LEHR, CRCM, is an industry
principal for Finacle, at Infosys
Technologies Ltd. For the 20-plus
years prior to this, he developed and
led compliance programs for a
number of banks and an online 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 (CRCM) through
the ABA Institute of Certified Bankers. Reach him at
stu.lehr@gmail.com.
And the Bobbly goes to….
IHAVE DECIDED TO CREATE A NEW AWARD—THE BOBBLY— which signifies when a bank has really bobbled a regulatory requirement. (Needless to say, I will need to order a large number of them.) I got the inspiration for this statuette based on my own bobble-head that a friend
ordered online for me (from some company in China, apparently you just
need to send them front and side photos of the person’s head).
