Know Before You Buy
Not all compliance providers or compliance products are alike. That might seem obvious, but they generally fall into two groups. And you already know enough to tell the difference.
How? Because you now know that creating Policies, Consumer Notices and the other materials required for compliance is Step 3 of the Compliance Ladder. And that's because all those documents have to be tailored to your specific activities – which means you first have to determine which particular requirements apply (Step 2).
Take the Federal Privacy Rule: Your Privacy Notice must accurately describe the reasons you share consumer information with third parties. You and a competitor across town may differ in these respects, and that means your notices must be different, and you may be required to deliver the notices at different times.
Yet most companies selling compliance products try to skip Step 2. They figure since you're an accountant, or auto dealer, or financial adviser, they can just sell you the same policy, notices and training materials they sell to an accountant up the street, or an auto dealer across town, or a financial adviser in a different state.
We can't stress enough: That's not sufficient for Compliance. Regulators expect you to know which particular requirements apply to you (Step 2).
In any regulatory audit or examination, the regulators will request your written Policies, your training materials, consumer notices, and procedures. Why? They want to see if you've identified the actual requirements that apply to you, and are taking sufficient steps to ensure compliance.
So how do you determine which particular requirements apply to you ( Step 2) and get the tailored documents that regulators require (Step 3)?
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