Robert Fulghum recently released the 15th anniversary edition of his book All I Really Need to Know I Learned in Kindergarten. The book‘s longevity is due to one simple fact: It’s true. This might not be the first place you look for guidance when tomorrow at 9 a.m. an examiner from the Department of Financial Institutions will be sitting in your office looking at loan files, but I recommend you come along and listen to what we learned as 5-year-olds.
WHEN YOU GO OUT INTO THE WORLD, WATCH FOR TRAFFIC. Hopefully, you’ve considered the health of your compliance system before today. The number of rules in the mortgage lending world has increased to rush-hour traffic proportions. Look both ways before you cross the street. If not, you will need to fall back on another one of Fulghum’s truisms: Clean up your own mess. Shore up your compliance efforts today and make sure you apply the appropriate resources to the task. If you need help, ask for it. A simple Web search or a phone call to a colleague will turn up a number of good compliance experts.
SHARE EVERYTHING. During an on-site examination, the examiner needs a workspace—usually a phone and desk will do. Some use laptops and will ask for an additional monitor for viewing files if you provide themin an electronic format. Have the space ready when the examiner arrives. I prefer a space near my office, but away from production and operations.
WARM COOKIES AND COLD MILK ARE GOOD FOR YOU. When the examiner arrives, show him where he can get coffee, water or snacks; how to get to the restroom; and ask if he needs anything else. If he provided a list of documents or an officer’s questionnaire beforehand, have those items ready when he arrives.
PLAY FAIR. In other words, give the examiner what he asks for. Of course, you want to spend some time in your files understanding if there are issues and clearing out unrelated or unnecessary documents. As we noted in last month’s article, everything an examiner knows about a file comes from its documents. Help him follow along with each file’s story by including all the necessary documents and removing the distractions.
The examiner has a job to do and providing him with what he needs will shorten the examination process, build confidence in you as a knowledgeable, honest professional, and let him know that he will receive the level of transparency necessary to complete the examination.
SAY YOU’RE SORRY WHEN YOU HURT SOMEBODY. No lender follows every rule perfectly every time. Eventually, an issue will arise. When it does, re-emphasize that you want to comply with the rules, you make a genuine effort to comply with the rules (assuming you can prove that) and you will make the necessary changes to better comply with the rules in the future.
Fulghum has a few other bits of advice from our early years. In or out of the examination context, they make life a little easier if we follow them:
Don’t hit people. Put things back where you found them. Don’t take things that aren’t yours. Wash your hands before you eat. Flush. Learn some and think some and draw and paint and sing and dance and play and work every day some. Take a nap every afternoon. Hold hands and stick together. Be aware of wonder.