As we’ve learned from consumers during the COVID-19 pandemic: Banks need to seize this digital moment before they become mere marketplace memories.Digital transformation is no longer a “nice to have” for small and medium-sized banks. Consumers have flocked to digital channels in record volumes since lockdowns rolled out across the country earlier in the year. Branches are seeing declines in in-person visits, while one Mastercard study showed 40% growth in contactless transactions in the first three months of 2020.
No longer are we talking about a digital-first approach. To meet these rapidly evolving customer preferences, banks need an end-to-end strategy to integrate digital for significant gains – including increased operational efficiency, improved customer satisfaction and decreased regulatory risk. And let us not forget that bringing your bank up to at least market expectations for digital experience will enhance your brand.
Without question, the COVID-19 pandemic has also changed the daily work of banks – but the timing has never been better to reignite and focus your bank’s digital transformation to meet your customers’ needs. Asking three critical questions will help you build a just-right roadmap as you look for the best ways to assess, fortify and optimize your systems to move to the next level.
Spend time reviewing your budget and transaction metrics, which can help you identify opportunities for investment and establish benchmarks to measure against as your digital journey advances. An important part of this initial assessment is aligning on key definitions across channels, which, in turn, will drive consistency in future reporting. For example, do you consider a married couple as one customer or two? What if they have both individual and joint accounts? Is your customer total still at one – or are you up to four now?
Fight the urge to have a digital strategy. Instead, you need an integrated channel approach that supports your overall strategy. Take the time to understand where and how you’re investing in your primary customer channels: branch, phone, ATM and digital. At the end of the day, this should be a zero-sum game: As you pick up customers in one channel, volume should drop in others. As digital gains more traction, you should start to see cost savings from greater automation and operational efficiency – or you need to figure out why you’re not.
This is hard work, and you won’t succeed if the effort is contained just within the digital team or even if you rely on a few digital ambassadors. Getting everyone in your bank – from the CEO to the front lines – on board with driving greater customer usage in your digital channel takes both time and engagement. Your phone agents and branch tellers need to understand the benefits of digital products and services so they can educate customers.
Getting from Point A to Point Z – and taking all the right steps in between – can be a tough thing to balance. That’s why we developed our digital transformation playbook, How to Successfully Reclaim and Navigate Digital Transformation Amid COVID-19, to help you get a running start on developing the right blueprint for your organization. The playbook walks you through the steps to start your bank on a digital journey that will enhance your daily operations (read: save money via greater efficiency) and better meet today’s customer needs. Download your copy today.
Late last month, I had the pleasure of attending and facilitating a couple of on-demand panels for the American Banking Association’s (ABA’s) first-ever Risk and Compliance Virtual Conference.
Customer Channels & Operations Management, Data & Analytics, Risk Management & Regulatory Compliance 4 minute read
The Big Picture Pick up recent copies of The Wall Street Journal or American Banker, and you’ll see headline after headline about consent orders and hefty fines issued by the Consumer Financial Protection Bureau to mortgage companies caught using deceptive advertising practices. This summer alone, eight have been issued. Two things immediately strike me when I see these stories: Many of these cases didn’t have to happen. And while these particular consent orders were concentrated in the mortgage sector, similarly problematic issues are most certainly occurring in other lending segments across the financial services industry. After a hundred years or so, you’d think we would know how to follow regulatory rules –particularly those put in place to protect consumers. Indeed, the first such laws were framed by the states before World War I – although the first meaty federal law, the Truth in Lending Act, wasn’t passed until 1968. Every new regulation layered in since then largely continues to further shield consumers from unfair practices – which often start with glossy ad campaigns designed to get them in the physical or digital door. The reasons why we’re still struggling with compliance aren’t too difficult to understand: turnover within organizations, competing priorities, a lack of sound controls, new staffers who are unfamiliar with existing regulations, and a never-ending list of new ones, including Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) and the Mortgage Acts and Practices (MAP) – Advertising Rule. There’s also often a gap between the intent of any new regulation and how marketing teams interpret it. The risks of not crossing every “t” and dotting every “i” are significant, as evidenced by these recent consent orders. Doing things the wrong way also can mean costly penalties, time-consuming regulatory remediation, and loss of customer trust – which can translate into higher complaint volumes and even lawsuits. Let’s explore some long-lingering myths about how banks advertise their lending products – and, more importantly, what your financial institution should be doing. MYTH: Legal and Compliance don’t need to review my ad since I’m the expert in marketing. FACT: This is the biggest myth that persists in financial services marketing and advertising. Every word you use to communicate has specific and nuanced meanings, and your legal and compliance teams have a responsibility to protect your company and consumers alike. No external ads or marketing materials should be released until you get signoff from your legal or compliance team. It’s not any more complicated than that. MYTH: Our marketing team knows what Legal and Compliance have told us. We get it, but we need leeway to make our ads eye-catching and even a bit sexy so we can get business in the door. One little word change doesn’t really make a difference. FACT: Remember how former President Bill Clinton faced legal drilling over his interpretation of the word “is”? You’d be surprised at exactly what a bank must validate before it advertises anything as “free.” That word “free” – and countless more – are triggers, often requiring specific disclosures on how they apply to what you’re advertising right at that moment. Ideally, your marketing and advertising teams should collaborate almost daily with your legal and compliance teams. Of course there’s going to be some friction between the advertising folks, who see in every color of the rainbow, and the legal and compliance folks, who typically only see in black and white. The important thing is to build processes and procedures that enable effective and efficient reviews of all advertising and marketing materials, and that begins with concepts. When you involve those responsible with compliance up front, they can help rethink an approach in ways that ensure the final ad meets regulatory requirements. Also, try taking their early “no” to mean “not yet” and be open to ideas on what could translate into an easy reframing. But go to them at the end with an ad that fails on every compliance front, and their “no” will be just that. When I was at a bank that now has more than $30 billion in assets, my compliance team worked diligently to become a strategic partner to the marketing team. It took some time, but our peers came to see that we never aimed to derail their vision. As our relationship evolved, so did our interactions. In fact, we created a desktop resource that allowed marketers to easily look up the latest laws or match sales terms with the necessary disclosures, delivering a self-service tool that also empowered them to create responsibly and expedite the review process. Rest assured, the goal of your bank’s lawyers and compliance officers is not to thwart creativity, but to ensure that amazing ad concepts give consumers precise, clear information about the company’s products and services, allowing them to make smart financial decisions. Believe me: Compliance teams want powerful, compelling and even award-winning advertising that brings more revenue in the door, because when you have that, everyone benefits. MYTH: Our market competitor ran an ad just like that. If they got away with it, then it’s OK and the legal and compliance team is overreacting. FACT: This is the corporate version of your mother asking you, “If everyone was jumping off a cliff, would you do it, too?” The only truth here is that your competitor ran an ad. You don’t really know if that financial institution “got away with it.” In fact, you might learn not too far down the road that your competitor actually got caught red-handed with a compliance violation. After all, the underlying premise of advertising is to spread the word, and regulators are paying close attention. Frankly, you should be analyzing what your competitors are doing, but I’m not talking about their advertising. Take a good look at every consent order or other regulatory action you hear about and compare it to what’s happening in your shop. Are you doing things the right way? Are you identifying and avoiding the possible risks in your process? In other words, consider that the teacher has given you every answer to the test, and you don’t want to fail down the road. MYTH: The bank’s advertising agency developed that campaign – not our internal team – so we’re not going to get in any trouble. FACT: Time and time again, oversight organizations stress that any third-party vendor – whether it’s an ad agency or a cross-sell phone queue – is a seamless extension of your financial institution. If they get it wrong, so do you. You don’t outsource the compliance responsibility along with the work. MYTH: All of that applies to my bank or mortgage company – not to me as a loan officer. I’ll post a special offer on my social channels just for my customers. FACT: Your very title of “loan officer” means you’re an officer of your financial institution, and the same exact requirements apply to you. Without question, the growing influence of social media makes consumer outreach easy, but the brevity and ease of these same platforms also make it more difficult to keep your team members from going rogue. The same compliance standards apply to all of your advertising, including any unsanctioned materials. Every employee needs to understand this responsibility. (BTW, don’t forget about old-fashioned tactics, such as a quick sales flyer that a teller might create and post in a branch. Whether that flyer meets your advertising brand standards is the least of your worries, because you’re most likely out of regulatory compliance.) MYTH: Getting an internal review takes so much time that we’re losing competitive advantage. FACT: Doing it right takes a fraction of the time needed to fix things – particularly if you’re cited for a regulatory infraction – and maintains your institution’s reputation. Yes, a legal or compliance review is another step in your marketing process, but it’s a short blip in the lifetime of a successful business. In my previous role, I was intentional about building interactions with the marketing team that served everyone’s needs as efficiently as possible. If a federal agency comes at you with a consent order or Matter Requiring Attention, you’re going to spend significantly more time finding the root issue, solving for your misstep, gaining regulatory signoff and getting back to work. You also can’t rebuild consumer confidence overnight – even with the most attractive offers in your marketplace. After all, if your customers know you’ve been under scrutiny before, do you think they’re going to trust that you’re being straight with them this time around?
Risk Management & Regulatory Compliance, Compliance, Risk Management 5 minute read
Every year, tens of thousands of pages are published in the Federal Register, with a good chunk of themdetailing what banks need to deliver in serving their customers. In the past decade, the Dodd-Frank Wall Street Reform and Consumer Protection Act came in at the equivalent of nearly 1,000 pages and prompted several thousand more pages of rules and regulations, including, as just one example, the TILA-RESPA Integrated Disclosure (TRID) rules. Tack on relatedregulations published as a result of the Dodd-Frank Act,other more recent regulatory amendments likethose made to the Fair Debt Collection Practices Act (FDCPA), as well as state-specific requirements, and you’ve got enough paperwork to fill a library.
Risk Management & Regulatory Compliance, Compliance, Operational Efficiency 6 minute read
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