The Overwhelmed CCO
Chief compliance officers have a hard job. CCOs know that fact and them fully embrace the challenges of their positions. At the same time, CCOs have extraordinary expectations placed on their shoulders – they are rarely complemented about their programs while the company avoids any major controversies, but they are one of the first to be questioned when a compliance breakdown occurs.
CCOs are always busy. Everyone understands why – they have high expectations and often limited resources, outdated technologies, and competing, political demands on their activities.
I often witness this phenomenon. CCOs often explain that they rarely focus on their “to-do list” and spend most of their time “putting out fires” or responding to a senior executive’s demand. CCOs regularly complain that they get to the end of the day and have had no time to focus on their priorities.
This can be a trap. A CCOs performance is not measured by how busy they are – being busy does not necessarily translate into quality of performance. To put it bluntly, running from fire to fire does not necessarily mean that a CCO is doing a good job.
CCOs have to apply a cost-benefit analysis to their own activities. Warren Buffet and Bill Gates recently conceded that the most valuable commodity they have is their time. CCOs have to do the same analysis.
For CCOs the danger of being overwhelmed is significant. CCOs have a huge portfolio for which they are responsible and they often lack basic resources to carry out their job. Their difficulties are compounded by the fact that CCOs are dependent on the cooperation and performance of related functions in the company over which the CCO has no authority, e.g. human resources, finance, information technology.
CCOs have examine their specific responsibilities and tasks, and turn a critical eye to each and ask some basic questions.
Responsibility: Is this a task that I should be responsible for?
If not, who should be responsible for completing the task?
Accountability: Can I hold that person accountable?
Information: Do I need to know any information about the performance of that task?
Communication: Have I adequately delegated this task to the appropriate person and communicated my expectations as to performance?
This basic framework provides a way for a CCO to prioritize his or her responsibilities and then make sure that any delegation of responsibility is properly executed.
CCOs need to rationalize their activities, delegate where they can do so, or address specific needs in other ways – e.g. seeking assistance from another function or securing additional resources (human or technology).
An overwhelmed CCO is a risk unto itself – and CCOs need to guard against such a threat. It is easy to get lost in a job and it takes discipline to preserve a person’s ability to perform their job effectively.