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CCO Presentation Panic: Leading Up to the Board Meeting

By GAN Integrity

It’s that dreaded time: putting together the compliance report that goes out to the company’s board of directors the week before the board meeting. What does that mean? Long days and nights, and a scramble to collect data for the report. Specifically, it means that the primary activity for the week before the board materials go out consists of scouring spreadsheets, pouring through scores of months old email strings to extract data and identify gaps (followed by additional emails to close those gaps), and the final push of pulling the data together and putting it into PowerPoint textual summaries and graphs. And all of this is in addition to the regular chief compliance officer’s (CCO) ‘day job’.

It’s always a struggle – to get all the data, to get it right, and to then put into a form that is informative but digestible. And invariably, in the moments (often late at night) after the board materials have been submitted, there is a revisiting of the same questions: Is this the best use of my time? Why am I always in this scramble mode before board meetings? Is accurate and complete data actually reflected in the report, or am I missing something? What resources could I utilize to decrease the time involved with, and improve the overall quality of, the report?

The question of adequate resources is one that CCOs typically face as part of the job; there will almost always be an “agreement to disagree” between a company’s chief financial officer and its CCO on this issue. Recent US Department of Justice (DOJ) pronouncements provide support to the CCO position, and specifically identify the importance of adequate resources to compliance program operation, but the question is inherently subjective and a function of each company’s unique facts and circumstances.

But in terms of applying those resources, however limited, there is now technology available that can both reduce the stress associated with generating board reports and improve the quality of the reports: automated Software as a Service (SaaS) compliance management systems. Report preparation now essentially consists of identifying the type of data that will be the subject of the report, specifying the parameters, and choosing the visual representation. In the better systems, the underlying data resides within the system (or is available via seamless links to other programs (referred to as “application programing interfaces” or “APIs”) as the overall compliance program’s system of record.

The “normal course” benefits of having such a system are further accentuated in the event of a non-routine regulatory inquiry involving disclosure of compliance program operations and supporting data. There may still be some “nights and weekends” element to the response, but the time and cost savings of having everything in one place, among other positives, could be substantial.

Wake up and smell the roses, CCOs. Technology can help avoid revisiting those irksome questions that come from manually producing board reports, and help bring regulatory inquiries to quicker closure.

Image credit: Allan Rotgers, Flickr.

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