System and Operational Enhancements to Drive Compliance Management

Desired Capabilities

Regulatory Compliance
Operational Risk
Governance and Policy
Process Management

The Situation

A student lending organization needed to upgrade its compliance management system (CMS), after a regulatory agency issued multiple findings for operational deficiencies. However, the organization lacked the internal resources and supplemental expertise to support the CMS buildout and elevate related practices to resolve the regulatory findings. An external partner could deliver the needed remediation in both areas against an urgent timeline.

The Challenge

Develop and implement an enhanced CMS and best operational practices to meet pressing regulatory deadlines and establish the foundation for an internal compliance culture.

Meaningful Outcomes

Enhanced board and management oversight, including stronger risk and issue knowledge and remediation.
Developed robust consumer compliance policies and procedures.
Built and implemented a robust monitoring and testing program, with established metrics.
Designed and launched comprehensive consumer compliance training, which ensures the organization follows best practices and provides a better experience for consumer complaints.
Implemented stronger oversight of third-party service providers through robust reporting and monitoring that identifies and remediates issues quicker.

Our Approach

Spinnaker Consulting Group worked in tandem with the client to prioritize and integrate the work, setting up monthly goals and scheduling regulatory progress updates with stakeholders.

We kicked off the project by developing effective policies and procedures that shaped each enhancement, along with a robust program to train the board on oversight responsibilities, assessing risks and issues appropriately, as well as applicable laws and regulations.

Next, the team developed compliance management and governance frameworks to manage review and approval of future consumer policies and procedures. We prepared a risk assessment to prioritize implementation of the enhanced CMS.

In addition, we developed a new testing and monitoring program, assembled an enriched policy inventory, improved customer complaint responses and launched reporting to ensure an upgraded third-party management program remained in compliance. In the last phase, we implemented rigorous procedures, from the board to the front lines, to ensure that the organization had the operational structure to maintain consumer compliance best practices and resolve the regulatory findings.