March 20, 2023 | Maria Fritzsche
Estimated reading time: 9 minutes
Compliance Confessionals – How does a CCO stay organized?
Compliance expert and former Head of Compliance, Sylvia Yarbough, shares secrets and insights from the heart of the compliance team.
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I was recently catching-up with a former colleague and we spent most of the time discussing his new job and how great his new boss was but…(yes there is always a but even with the great boss). My former colleague, now reported to the Chief Compliance Officer (CCO) at a small but growing financial service organization. He had been trying to move up in the ranks at a behemoth of a bank with no success, so he took a leap of faith by going to a better role at a much smaller organization. Now he was in the front-row seat as a direct to the CCO and was observing firsthand the difficulties that even a very smart and savvy CCO can have in getting and staying organized. His new boss was constantly on the ropes — missing deadlines, unprepared for board meetings, overbooked and in general just very disorganized. He asked my opinion as to what I thought his CCO could do differently. Now I don’t know this CCO but I have been in the passenger seat in a prior life with a similar type of boss. I shared with him what I had done in a prior life to help my CCO and what worked and didn’t work. I figured I would share my thoughts and experiences in this arena with others who may find these tips useful.
Getting and Staying Organized
At some point, even the busiest executive who is finding him/herself out of control must stop and take stock in order to get organized.
1. Support Person
If you do not have a right-hand person who can help you with this effort, leverage your administrative assistant. If you don’t have an administrative assistant, find a smart individual on your team with a little capacity in their workload and a willingness to help. The upside is that they will benefit from getting the exposure to the inner workings of the CCO’s job.
You must be able to trust this individual because you will need to give them access to your calendar, your mailbox, and resulting confidential documents. So before engaging, make sure you have a heart to heart on confidentiality of information and the trust factor. If you are not 100% sure, you may start out with access to the calendar to start and build on that trust over time.
This individual ideally would be responsible for:
- Helping you clean up and keep your calendar up to date.
- Review your schedule with you once a week, looking out at least two weeks into the future
- Identify and block out prep-time for meetings
- Coordinate and organize the materials necessary for your meetings or that you need to review to respond to.
- Bring your attention to unplanned meeting invites and determine if they should be declined, accepted, or delegated
- Prepare summaries of reports or presentations if they have the skill sets.
Note: It will be incumbent on you to help this person do this effectively by not accepting every new invite that pops up or your calendar, or agree to every meeting you are invited to without checking your schedule.
Leverage the support person and undertake a review of your calendar:
- Look Forward for at least three months to identifying reoccurring meetings.
- Look backwards for at least three months to identify prior recurring and various other non-recurring meetings
- Obtain Committee meeting schedules that CCO typically is expected to attend from the various committee organizers (e.g., Board, Risk, Divisions, etc.). The backwards and forwards review should aid in spotting these committees and identifying the organizers.
Once this information is organized by recurring and ad hoc requests, the CCO must make some hard decisions. As in most organizations, there are a lot of long meetings and everyone wants the most senior individuals attending. As the CCO, you must make hard decisions on what meetings you can truly attend. It goes back to the old-adage you can’t please everyone all the time.
- Determine which ones you must really attend and ensure that they are scheduled out for the year if possible. If a committee organizer hasn’t set out invites for the year, add a Hold the Date for the event so that you don’t forget or run into a conflict.
- Are there committees that you can be replaced by a delegate? Identify the best delegate and communicate with the delegate and the organizer to transfer that responsibility.
- Are there committees that do not require compliance attendance but you or a delegate can be copied on meeting minutes and/or followed up if there are questions coming out of the meeting? If so, communicate to the organize the reason you should be removed and how you can continue to assist via email communication to you or preferably, your delegate.
Ad hoc/non-recurring meetings
- Identify if there is a pattern. If these non-recurring meetings seem to land on your calendar every few months so they are becoming recurring but not planned.
- Question if you need to be the participant? If so, you may need to contact the organizer and establish a more formal meeting cadence so that these meetings don’t continue to just pop-up on your schedule.
- If you don’t need to be the participant, identify if there is a delegate that the organizer can work with or communicate with in your place. Connect the delegate to the organizer to work out those details.
This is also the time to organize your internal meetings. They should be planned out for the year with standing dates and times. This not only helps you stay plugged in with your teams and direct reports, but also helps them be prepared to better engage with you.
Time Away from the Office
It is the most difficult to manage our personal time. But with the challenges of bigger roles, the more we must schedule our time away from work just like we schedule our time at work. At the beginning of the year and one quarter out, CCO and anyone should add to their calendars:
- Vacation time
- Doctor’s appointments
- Volunteer events
- Kids Activities
- Fitness/Gym time
Some may be just a Hold Date while you get it formalized, but the quicker you block the time off, the better.
Finally, block off office time. This is time that you are reserving to do the work you can’t do while sitting in meetings all day. This time should be considered precious and not given away based on the next seemingly import meeting invite.
Once you have identified all these dates and times, have your support person update your calendar – color coding is great. Review for conflicts and, if necessary, reach out to see if conflicts can be negotiated without giving up your office time or Time Away from the Office. Short of the Board and Risk Committees, most other standing meetings have a little flexibility.
We all like to believe we are the only ones that can handle things in our role. However, the best types of leaders should know when and who to delegate to. I am sure many of us have worked in organizations where we get the work delegated to us and take some pride in getting it done. However, a true leader will all so let their one and/or two downs have more visibility in the organization by delegating to them representation on committees, projects, and other formal or informal meetings requiring compliance presence.
- Identify which of your direct reports might be ready to step in for you at the next Risk Committee or Board Meeting that is scheduled the same week that you had planned to go to Cancun; Or, can represent you at another standing committee even if it is not in their wheel house.
- Ask your direct reports who on their teams are ready to represent compliance as part of the Governance/Oversight Committee on a large-scale project.
A good CCO will find there are not enough hours in the day to review every report and be present at every meeting. Figure out when it is appropriate to delegate and have you short list of who you can delegate to. With the proper coaching, prep, and trust, we can be amazed at what our team members are capable of if given a chance.
For those CCOs who are new in their role or came up in the ranks and are used to preparing their own presentations, reviewing reports, and responding to every request in your inbox. This is the time to challenge yourself with delegation.
- Resolve yourself that you do not have to put the finishing touches on every presentation or report before it goes out. Build a tag team between the SMEs on your teams and other team members who are detailed oriented.
- Identify the person on your team that can review that 50-page document and provide you with bullet points summary so you can be prepared for the next meeting. Same goes with presentations – get someone on your team to summarize the material into the key bullet points, we all know there is never enough time to cover all the materials in any committee meeting.
- Requests, from other departments, should be sent to the appropriate delegate to research and get a response back to you or out to the requester with you copied. You do not have to answer everything personally. But don’t forget to acknowledge receipt and that someone will get back to them shortly.
For Delegation to work effectively, you will need to spend some time on prepping. Leverage those blocked office times to ensure that a day or two before a meeting, you have had time to prepare sufficiently for a meeting, especially if you are presenting.
- Your support person should ensure time is blocked on the calendar for the prep sessions and materials have been provide
- Prep-time may include a 30-minute session with the delegate who prepared the materials to review to ensure clarity and understanding.
- Often adding some handwritten notes will help you retain key points.
- Ensure you have all materials with you or accessible online in advance of the meetings.
To close, I know it is easier said than done but if you find yourself constantly overwhelmed, late on deliverables, not prepared for meetings, overbooked, etc. put some of these practices in place and keep at it. You may find it takes a while, but eventually you will rein it in and find yourself still running fast — but at least down an organized path. The plus here is that by engaging your team members in helping you manage the day to day, they will get more exposure and understanding of the bigger picture.