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If you have ever watched a major boxing match, you probably know the phrase.
“Let’s get ready to rumble!”
The lights are on. The crowd is ready. The fighters are in their corners. Everyone knows what is coming next. But imagine hearing those words when you aren't ready to fight.
That’s probably a little closer to how it feels when you find out an auditor or examiner is coming. It could be a state regulator, or it could be the due diligence team from your capital provider. In either case, being unprepared is a good way to get punched in the face. Suddenly you're seeing stars!
Are our policies current? When was the last time we did training? Where are our complaint records? Did we complete our annual review? Who has access to customer information? Are we actually following the procedures written in our policies? And perhaps the most dangerous question of all:
Where is that document?...
An audit has a funny way of turning things we have been meaning to get around to into things we need right now. But here is the question worth asking:
Why does an audit have to be the thing that gets us ready?
Compliance shouldn't be something we clean up when we hear someone is coming. The goal should be to operate in a way that, if someone called today and said they wanted to take a look, we wouldn't have to scramble.
Think about your dealership right now.
· Could you produce your current Information Security Program?
· Your Red Flags program?
· Your privacy notices?
. Adverse Action notices and proof they’ve been mailed?
· Your complaint records?
· Your training records?
· Your policies and procedures?
Could you show not only that those documents exist, but that the dealership is actually following them?
That last part matters.
Having a policy sitting in a binder or saved somewhere on a computer is one thing. Being able to demonstrate that employees have been trained, reviews are being performed, problems are being documented, and procedures are actually being followed is something else entirely.
You don't want the first time you discover a hole in your compliance program to be when someone outside the dealership discovers it for you.
So maybe this week's challenge is simple. Pretend you just got the call. An auditor is coming.
What is the first thing you would be worried about?
Whatever immediately came to mind might be a pretty good place to start.
Because when someone finally says...
“LET'S GET READY TO RUMBLE!”
Hopefully, you're prepared. Contact us at info@ignitecp.com if you need someone in your corner.
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