Halloween and Compliance

A compliance professional can turn the fun and chaos of Halloween into a boring night on the study of procedure. Here, I’ll prove it.

Let’s start with costumes.

Have you imposed a “no costume = no candy” rule. Perhaps you merely skimp on the older kids who have skimped on dressing up. If you, like me, are suddenly living in winter you need to figure out what do with the kids who are all bundled up fighting the cold. They might all look like Eskimos tonight instead of zombies and superheroes.

Perhaps you are afraid to skimp because those older kids who didn’t put much effort into a costume may put more effort into toilet paper and eggs. Are you willing to compromise on your rule because you are afraid of the repercussions. How would that reflect on your compliance program?

Let’s move on to technology.

What about using Halloween metaphors to remind yourself about protecting your computer? Try the FCC:

  1. Are cyber ghouls and online scammers feasting on your computer? This Halloween, learn how to stop them at OnGuardOnline.gov.
  2. Don’t let someone decide to be you for Halloween. Read more about online identity theft at OnGuardOnline.gov.
  3. Don’t let computer security worries haunt you at night. OnGuardOnline.gov says download software updates and patches often.
  4. Garlic? Stake through the heart? OnGuardOnline.gov says only the latest security software protects you from online vampires.
  5. Zombie warning! Update your security software often to protect your computer from zombie bots. Read more at OnGuardOnline.gov.
  6. Don’t let old security software spook you. Keep firewall, anti-virus, and anti-spyware software updated, and visit OnGuardOnline.gov.
  7. Beware of online tricks this Halloween and enable your computer’s firewall. Find out more at OnGuardOnline.gov.
  8. Don’t let a virus ruin your computer’s Halloween spirit. Visit OnGuardOnline.gov for tips to keep your computer virus-free.
  9. Don’t be a “phish” for Halloween. Visit OnGuardOnline.gov to learn how to spot computer scams that try to hook your personal info.
  10. When you tell kids about Halloween safety, tell them about online safety too. To learn how, read Net Cetera at OnGuardOnline.gov.
  11. If you leave your laptop for ‘just a sec,’ it could become someone else’s Halloween treat. Visit OnGuardOnline.gov to learn more.
  12. Can you spot an internet scam dressed up as a great deal? Visit OnGuardOnline.gov for tips on how to spot online frauds.

And let’s put a little scare into you while your little ones are running around the neighborhood.

A team of local law enforcement agencies in Milwaukee are going door-to-door in search of sex offenders who are breaking their compliance rules.  “Offenders are not allowed to have anything related to trick-or-treating that includes bowls of candy Halloween decorations, pumpkins. They can’t have their porch light on indicating that the residence is participating in any trick-or-treat activities,” said Melissa Othmer of the Department of Corrections, Probation and Parole.

Boo!

The jack o’ lantern Death Star is by Noel Dickover with instructions on his site, Fantasy Pumpkins, on how to create one yourself.

Weekend Humor: Dodd-Frank Update

Jon Stewart helps celebrate the one year anniversary of Dodd-Frank (for those of you who grew up on Schoolhouse Rocks.)

Fourth of July and Compliance

What better way to celebrate the independence of the United States than by taking the day off from work, grilling meat, and watching stuff blow up.

In colonial Boston, official proclamations were read from the Old State House balcony, looking down State Street towards Long Wharf.

Each July 4th, the Captain Commanding of the Ancient and Honorable Artillery Company reads the Declaration of Independence from the balcony of the Old State House. The reading of the Declaration of Independence dates back to July 18, 1776, when Colonel Thomas Crafts performed this duty for the first time.

Bruins and Compliance

I never thought the Bruins would win a championship under the current ownership. For the Celtics, Red Sox, and Patriots, it took a change of ownership for them to become championship caliber. The “Tone at the Top” was to win the championship. Nothing else was acceptable.

The owners of the Bruins had been accused of having the team be just good enough. That is, good enough to keep attendance up to sell beer and popcorn.

It’s been thirty-nine years since the Stanley Cup has been in Boston in the hands of a Bruins player, since the days of Bobby Orr and Phil Esposito in black and gold.

Boston Globe Staff Photo / Jim Davis

The Case for Executive Assistants

Why would you pay managers big salaries and then ask them to make their own hotel reservations?

Since it’s Administrative Professionals Day, a story in this month’s Harvard Business Review caught my eye: The Case for Executive Assistants. (Now looking at the Administrative Professionals’ website, I see it has grown from being mere a day to become an entire week.)

Technologies like e-mail, voice mail, mobile devices, and online calendars have allowed managers at all levels to operate with a greater degree of self-sufficiency. At the same time, companies have faced enormous pressure to cut costs, reduce head count, and flatten organizational structures. As a result, the numbers of assistants at lower corporate levels have dwindled in most corporations. That’s unfortunate, because effective assistants can make enormous contributions to productivity at all levels of the organization.

The author does some simple math to justify the cost of administrative assistants.

Consider a senior executive whose total compensation package is $1 million annually, who works with an assistant who earns $80,000. For the organization to break even, the assistant must make the executive 8% more productive than he or she would be working solo—for instance, the assistant needs to save the executive roughly five hours in a 60-hour workweek.

Of course, lots of the burden for getting that productivity boost lies with the executive/manager. You need to delegate wisely.

It’s a great, short article and timely. Unlike most content from the Harvard Business review, this article is available for free. (At least for today.)

Free Will and Compliance

“Human Irony” from Saturday Morning Breakfast Cereal

Heisenberg Uncertainty: Published by Werner Heisenberg in 1927, the principle implies that it is impossible to determine simultaneously both the position and the momentum of an electron or any other particle with any great degree of accuracy or certainty.

Read a Free Book

I have an extra copy of All the Devils are Here by Bethany McLean and Joe Nocera.

They put together an insightful look at the many factors that created the housing bubble and amplified the destruction when it popped. Pundits and purists have tried to pin the blame on a single element. It seems clear that many “devils” were at work. It’s not just institutions that failed in the crisis. The authors paint the pictures of key individuals who helped inadvertently build up the housing bubble or allowed for it cause mass destruction.

I thought it was a great book, but I don’t need two copies sitting on my bookshelf. If the book is on your reading list and you have not yet purchased it, here is a chance to get a free copy.

To enter the giveaway,

  1. leave a comment in this post, or
  2. send a message to my contest email address [email protected].

[button link=”mailto:[email protected]?subject=Contest Entry” color=”red”]Enter the Contest[/button]
The entry deadline is February 21, 2011. I’ll randomly pick a winner from the entries I receive by the deadline. If you are the winner, I’ll contact you for your mailing address.

Looking at the Residential Mortgage Crash

Matt Phillips at WSJ.com’s Market Beat put together some great charts showing the problems with the residential mortgage market: Fannie and Freddie: The Saga in Charts.

The first one that caught my eye shows how Wall-Street took such a quick, big chunk of the market share of residential mortgage-backed securities during the housing boom.

Fannie Mae and Freddie Mac’s share of mortgage-backed securities issuance plummeted from 70% to 40% during the housing boom. We have seen in many companies and markets that rapid growth comes without a similar growth in market controls and compliance. I think the lack of market systems and compliance contributed to the crash. It’s hard to understand the market when it barely existed a few years earlier.

Did Wall Street take business away from Fannie Mae and Freddie Mac? It looks like Freddie Mac and Fannie Mae’s origination activity was relatively stable. The private mortgage-backed securities were tapping into a new market.

As Joe Nocera and Bethany McClean noted in All the Devils are Here, the vast majority of that subprime activity was refinancings or second home purchases.

For those trying to pin the blame for the 2008 Crisis on Fannie Mae and Freddie Mac theses charts point in a different direction. Not that Fannie Mae and Freddie Mac are without blame, it’s clear that Wall Street excess carries a big chunk of the blame.

The last question, and the last chart, help answer the question of whether we need Wall Street in the mortgage business.

The answer seems to be yes. There are not enough deposits in the banks to cover all of the outstanding US home mortgage debt.

Celebrate Valentine’s Day with a Regulatory Twist

As someone who stares at a lot of regulations, this Valentine’s Day message caught my eye. If you are a fan of NPR, they have several other ways to share Valentine’s Day with an NPR flavor.

And don’t forget about the compliance issues you can run into. Dan Schwartz compiled a bunch of bungled romance issues in Employers: Think Your Competition is Tough? Watch Out for the Valentine’s Day Card.

UPDATE: The obscene and indecent material restriction is 47 C.F.R. 73.3999.