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Compliance program reporting is undergoing dramatic change. Periodic reports based on compliance program status data that was weeks old used to be the norm – for presenting to management or the board, or around budget time.
If there was litigation or a regulatory inquiry or investigation, other compliance-related reports would be produced, often involving a high volume of staff and outside professional billed hours compressed into a relatively short time frame.
Various tools have historically been used (and in many cases are still used) by the Chief Compliance Officer (CCO) in generating these reports – all paper or stand-alone systems based. And the common denominator was the CCO, pulling data from various sources, analyzing it, and then placing the result in various text, spreadsheet and/or graphics report formats.
Now, however, the needs are different and in some cases, they are real time. This paper explores various current use cases. The common theme: There is too much time and risk involved with managing a compliance program in 2016 using email, spreadsheets and sticky-notes. Certain software-based systems offer an integrated approach that produces far better and more reliable data in much less time.
The fact is that a software-based system joins the different types of information from the different sources in the required time frame and provides the CCO with the needed data, timely and detailed. So let’s consider what type of information is important to whom, for what reasons, and in what time frames?
(1) Program management info are critical for CCOs: To successfully manage the company’s compliance program, the CCO obviously needs to be up to date on training and communication activities of employees.
(2) Program supervision and oversight info are critical for senior management and the board: This depends on the CCO’s ability to provide the company board with accurate oversight and the management with information pertaining to implementation and supervision.
(3) Information on the existence and operation of a compliance program to value chain partners and third parties: This mainly provides assurance and guarantee that your company is compliant.
(4) Compliance is playing program reporting catch-up for CCOs: As CCOs are increasingly asked to generate program reports, the process will rather be one of collecting, processing and reporting… and repeating.
Exploring the different types, sources and recipients of information makes the relevance of a software-based system generating the required reports within the required time frame to the CCO, in a timely and detailed manner all the more necessary.