Who Owns Regulation Z Compliance?

By Pat McGrew, EDP, Kodak

In this era of Regulation Z in the US and similar regulatory changes around the world, most enterprises will be required to adjust their customer-facing bills, statements and regulatory notices with an eye toward bringing them into compliance. If you have been tracking Regulation Z, you know that it dictates font sizes for certain types of information and adds new requirements for information to be provided on page one of the loan or credit card billing statements. For companies using Monarch or Letter/A4 size page formats, these changes will likely require a massive redesign.

The starting questions are, who owns the design of the billing statement? And who will be responsible for ensuring that it meets regulatory requirements as well as brand requirements?

These might seem like easy questions to answer, until you try to answer them. Compliance issues usually sit in the Legal Department or Compliance Department. These folks are tasked with knowing the rules and ensuring that the corporation meets those rules. Their expertise is in the law, but this time around the regulatory changes are dictating design changes to core customer communication.

If you think the product line owner also owns their billing documents–as they do in some organizations–is that product line owner responsible for researching and enforcing Regulation Z requirements? That is a large responsibility to put on their shoulders! However, they have the best view into the billing systems and composition systems that join to push the bill into the mail stream.

Someone needs to be the designated lead in remediating for these changes. An approval process will be needed that not only speaks to the requirements of the brand, but also to the compliance requirements. These changes will touch the billing system, the core document design and the formatting requirements. Who is responsible for ensuring that design changes, both now and in the future, are compliant with Regulation Z? Who is ensuring that the requirements for new information provided to the consumer are met, and who is ensuring that as they are met the core branding is maintained? If you can’t answer these questions, there will be challenges to face as deadlines approach.

If you are already doing Regulation Z remediation, you may have already sorted the issues, but have you put the process in place that ensures on-going compliance? Have you ensured that the approval process now includes meeting a compliance checklist in addition to product line and billing checklists? And, who has the job of ensuring that any pre-printed stock that has Terms and Conditions is being updated to meet the new regulations?

That brings us to the end of this episode. Come back next time and let’s talk about how to ensure that bringing the bills and statements into compliance is done with an eye for protecting the brand.

Pat McGrew, EDP, is the Data-driven Communication Evangelist at Kodak. Her e-mail address is Pat.McGrew@kodak.com, Twitter is PatMcGrew, and her blog is at http://patmcgrew.growyourbiz.kodak.com.