Building an effective compliance team for a successful lending business involves individuals with mortgage industry experience, technological proficiency, and a balanced mindset.
Building an effective compliance team is a crucial yet challenging aspect of operating a successful lending business. Finding the right people with the perfect blend of skills, experience, and mindset can make or break your compliance efforts, and by extension, your institution.
We spoke to Mortgage Cadence Director of Compliance, Melissa Kozicki to find out what she thinks about when making staffing decisions.
“When it comes to core qualifications, mortgage industry experience is invaluable,” she told us. “The lending space is incredibly nuanced - perhaps more so than any other field outside of healthcare. Having team members who have been processors, underwriters, closers or loan officers provides vital first-hand context around the consumer finance processes being regulated.”
But that, she told us, was just the beginning.
Institutional knowledge ensures compliance programs aren't established in a vacuum separated from operational realities. Those with hands-on mortgage experience can apply a consumer-first mentality and surface potential compliance pitfalls before they become issues. The rules and regulations can be learned, but the essential business context is harder to teach especially since it can vary so widely from institution to institution.
At the same time, compliance also requires technological expertise in areas like change control, horizon scanning, data management, workflow automation, and reporting. You need team members sophisticated enough to structure and leverage technology to drive efficiencies. This blend of tech savvy and industry acumen is challenging to find.
However, Kozicki said the most underrated component of compliance hiring may be assessing the right attitude and mentality.
“Compliance isn't just mastering rules - it's a mindset of balancing risk management with facilitating legitimate business objectives,” she said. “You need team members who can be defenders when necessary but also opportunity enablers.”
This requires a mix of risk aversion and opportunistic thinking.
Kozicki says an ideal compliance professional is able to take a step back, truly understand leadership's strategic goals, and then advise on how to achieve those responsibly within regulatory guardrails.
“It's about working collaboratively instead of rigid, check-the-box enforcement. That doesn’t mean you are looking to hire someone who just agrees to everything. A good compliance officer knows when to takes a stand against leadership to protect their company, and when to execute on leadership’s directives”.
Identifying candidates with this balanced compliance mindset is difficult but key.
“Look for signs of critical thinking, candid communication skills, and ability to build partnerships across functions,” Kozicki advises. “A black-and-white approach to lending rules won't cut it - you need people who can navigate nuances and adapt as situations change.”
This may sound like demanding unreasonable malleability. But for compliance to be effective, its sole responsibility must be enabling the company to operate compliantly according to the official policies set by leadership - no more and no less. Personal stances on the "right" level of risk-taking only create inconsistency.
At the end of the day, Kozicki says high-performing compliance team members defer to management's position with objectivity and commitment to protecting the business. They aren't there to override leadership's strategic direction, but to help it be executed in a defensible manner.
Identifying candidates who can find that balance between enabler and protector isn't easy.
“There's no perfect scoring rubric - even seasoned compliance leaders make hiring misses,” Kozicki says. “But prioritizing mortgage experience, technical and communication skills, and an understanding of working seamlessly alongside leadership goes a long way.” One of the hardest lessons to learn as a manager in any area is to cut your losses early – if you have made a hiring mistake don’t perpetuate it through the years. Try to find a more suitable position for that employee in your organization or cut the cord if necessary.
Ultimately, compliance staffing is about finding professionals capable of responsibly mitigating risks without obstructing legitimate business aims. It requires a special type of mindset. One that can see both sides of the compliance equation and unite them towards a common goal.
To find out more about the compliance team we’ve built at Mortgage Cadence and how it works to help our lender partners build stronger businesses, reach out to us today.
By Melissa Kozicki, CMB, CMCP, Director of Compliance at Mortgage Cadence
Follow us on LinkedIn to be notified when our next article is released.
Mortgage Cadence:
Alison Flaig
Head of Marketing
(919) 906-9738