By: Sarah Stevenson.
Oftentimes when I am asked my educational background and I respond with; “Well, I have a Bachelor of Fine Arts…” I am stopped short with the following question; “How on earth did you end up in Compliance and what does Art have to do with Compliance?”
I have been pondering this question after mulling through 2000+ pages of proposed mortgage regulation and came up with the following conclusion.
Compliance involves a significant amount of research as we all know. Whether researching Regulation Z, Subpart F for specific rules on private education loans or Regulation CC for how long you can place a hold on a check a significant amount of a compliance professional’s time is spent on research. The same is true for an artist. As artists, art historians and curators, research is always involved. Before starting a new painting I may study and research another artist’s technique or use of mediums to get my desired outcome. In curating a show or writing a report on a particular movement or artist significant research is involved before one can even begin to explain a particular artist’s technique or why they painted this particular image or perhaps why an artist repeated a color in much of their work, such as Johannes Vermeer and his use of lapis lazuli or natural ultramarine in his paintings when really no other artists of his time were.
While ever frustrating at times art and regulatory compliance are open to interpretation. One may spend hours observing and studying a particular piece wondering what the artist meant and interpreting the piece as a struggle the artist may have had or sense a feeling of anger based on the use of red, when another may feel the use of red was a feeling of passion the artist wished to portray.
The CFPB continues to push out proposals with the purpose of making disclosures easier for consumers to understand while we on the other hand sit at our desks sifting through the outpouring of words and documents trying to make sense of it all and really not interpreting these changes as consumer friendly. We all can read a regulation but we can all interpret it differently.
Artists and compliance professionals must be able to take criticism and accept it for what it is and if unable to accept it, be able to defend our position. Artists face critiques from their peers on opening night of their new gallery show. Critics who attend the show may despise their work expressing their distaste in their formal review or they may grill the artist as to what the “meaning” behind their exhibit or a particular piece is even after reading the artist’s statement about the exhibit. Art students displaying their Senior Exhibitions are faced with potentially harsh critiques from professors and their fellow classmates after spending four years working towards their Senior Exhibition. An artist will stand behind their work, however difficult it may be, taking the criticism and facing it head on defending their position and possibly even using some of the criticism in preparation for their next exhibition.
Compliance professionals face similar criticism. After spending countless hours researching, reading and interpreting a regulation we must then present it to various business units in order to implement appropriate changes based on the requirements of the regulation. Compliance professionals are often not the most “popular” person in the credit union and we must accept that. We meet with the department heads presenting the regulatory changes; changes to documents, time limits, disclosure requirements, tracking requirements and the list goes on. We are often met with resistance and are often criticized because we are the messengers but we must defend our positions in knowing that we are presenting what is required of us as a credit union.
Artists and compliance professionals are often told we are too literal or too abstract in our thinking and that is okay. I have discovered whether you are an artist, a compliance professional or both, like me, we can all be considered a “compliance artist”.
Sarah Stevenson is the Compliance Manager for a Michigan based credit union. She can be reached at firstname.lastname@example.org