WHAT IS CORPORATE COMPLIANCE?
According to Corporate Compliance, Ltd., “a corporate compliance program is a system which is designed to detect and prevent violations of law by the agents, employees, officers and directors of a business.” At GLF, we’ve expanded this definition to include a Quality Assurance component that ensures that our firm is also in compliance with the standards communicated by our clients as well as our internal policies and procedures. Thus, legal and operational compliance is a major component of our business strategy.
WHY IS A CORPORATE COMPLIANCE PROGRAM NEEDED?
Collections & CreditRisk Magazine reports that Fair Debt Collection Practices Act lawsuits filed against collection agencies and creditors have grown steadily in recent years. Fair Credit Reporting Act lawsuits have also increased, while Telephone Consumer Protection Act lawsuits are increasing at a reported “explosive” rate. Couple these findings with the myriad state and federal regulations imposed upon creditors across all industries, the Consumer Financial Protection Bureau, with its sweeping coverage and enforcement powers, and it is easy to see why an effective Compliance Program is a business necessity.
WHAT ARE THE ELEMENTS OF AN EFFECTIVE CORPORATE COMPLIANCE PROGRAM?
Given the rise of certain high-level corporate scandals involving financial shenanigans, and most recently, the “Robo-Signing” of Affidavits and other legal documents rampant during the mortgage crisis, it has become imperative for corporations, their outside counsels and collection agents to employ policies and systems to prevent these occurrences. The authorities differ somewhat as to content, but the essential elements of an effective Corporate Compliance Program are:
Written Policies, Procedures and Compliance Standards;
High Level Management Oversight of the Compliance Program;
Third-party (Outside) Review of Management;
Communication and Training of Compliance Standards;
Auditing and Evaluation of Compliance with Standards;
Accountability, including Disciplinary Measures for failure to comply with Standards; and
Effective Implementation of Corrective Measures, if needed
HOW DOES GILL LAW FIRM'S COMPLIANCE PROGRAM MEET THE ELEMENTS OF AN
EFFECTIVE CORPORATE COMPLIANCE PROGRAM?
Gill law Firm is subject to the written standards enumerated by its clients in its written agreements and work standards with each individual client. The Firm is audited annually or as required by each client in the main areas of:
(1) Legal and Regulatory Compliance
(2) Financial Compliance, and
(3) Operational Compliance
The audits are conducted by third-party auditors and/or the client’s designated agents to ensure transparency. GLF has achieved a 100% pass rate on all external, third-party audits conducted on its business practices.
The firm has enumerated, written work and compliance standards for all aspects of its business including the categories above, and employs internal measures to self-audit. The internal compliance feature is an on-going, daily process at GLF. All of the compliance standards are buttressed by a system of ongoing training in all areas subject to audit. The training is conducted by a dedicated Training & HR Coordinator drawing from sources such as :
Industry Groups like NARCA
Workforce management partners such as ADP
Internal, proprietary training
Thus, through written policies and procedures, rigorous training of the standards, independent, self-auditing of those standards, and intelligent implementation of any needed corrections, GLF assures our clients that in addition to meeting or exceeding their external audit standards, we are also vigorously self-governed.