ECM Software’s Value Hits Home with Financial Institutions When the Consumer Financial Protection Bureau Comes a Knockin’
Last week, the Wall Street Journal reported that examiners from the Consumer Financial Protection Bureau (CFPB) will knock on the doors of more than 100 banks in the coming days, requesting access to each bank’s books and records to determine if those financial institutions are complying with federal consumer finance laws.
Which begs the question, are you ready if the CFPB lands on your front porch? Can you quickly access the critical documents and consumer information the CFPB will request?
The CFPB, which officially opens for business on July 21 (tomorrow!) was established by Congress to protect consumers by carrying out Federal consumer financial laws. The bureau is charged with “making markets for consumer financial products and services work for Americans—whether they are applying for a mortgage, choosing among credit cards, or using any number of other consumer financial products,” according to the CFPB’s official website.
The Bureau was formed in the wake of the financial turmoil and economic crises in 2008 and 2009 as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Its jurisdiction includes banks, credit unions, securities firms, payday lenders, mortgage servicers, foreclosure relief services, debt collectors – just about every financial services company you can think of.
In short, the CFPB is an organization that financial services companies should get comfortable working with. And to do so, they will quickly figure out that a document management strategy and an enterprise content management (ECM) solution will be key to their compliance success.
ECM has been around a long time in banking. In fact, OnBase was originally created for a bank to help electronically capture and store check images. But in order for an ECM solution to effectively help banks answer the demands of the CFPB, very specific capabilities must be offered – not just scan and store.
Specifically, I’m talking about making sure that documents are secure, auditable, traceable and easily accessible. To do so, an ECM solution has to offer advanced capture capabilities to allow a user to quickly acquire and classify document images, Office documents like Word or Excel, PDF, reports, video – just about any type of document.
Many times, the value of the classification process is overlooked. A nice looking interface is great, but you won’t be able to find anything if you can’t assign granular metadata to documents within key fields like Customer/Member Name, Account Number, Loan Number.
But for an audit, perhaps the most important part to consider is the document retention. When you’re fulfilling audit requests, you need to make sure that your information is maintained according to its specific retention policy. In other words, it’s not a matter of having every single piece of information ever created, but rather having only the right kind of information.
To automate this retention process, ECM should enable users to simplify the creation and management of retention plans for electronic content organized within the system. Automating document retention will provide consistent disposition and allow your organization to respond to audit requests and legal concerns without hesitation
While some of these IT capabilities might seem basic, advanced content management with full-blown metadata and retention policies aren’t something that most banks have 100 percent completed. As successful engagements with the CFBP become critical to the survival of the banking industry, I strongly urge banks to at least have an understanding of their current technologies and their effect on retention. It could make the difference between having a successful CFBP audit and a failed one.