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Three Years Later - The Song Remains the Same...

Three Years Later - The Song Remains the Same...

Mitch Avnet
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January 4, 2016

Building a Compliance Professional Services Organization


Are we Hipster Chic?

This past weekend I frequented a hipster coffee shop in Greenwich Village.   As I drank my “chichi” cup of coffee, I couldn’t help but overhear the conversation at the table next to me.  It was two young gentlemen discussing how the nuances and imperfections of vinyl improve the overall music “listening experience”.  I silently chuckled to myself and began to feel very nostalgic.  Long before the Internet, Pay-for-Music Services, MTV, etc. the only way we could connect with bands we loved was through their albums, album art, band photos and the lyric sheets that were on the album jacket.  The resurgence of vinyl in stores such as Urban Outfitters and the pending relaunch of Columbia House (for Vinyl Albums)-  illustrates a very important point – people will always want the ability to connect to something they believe in. 

Get the Led Out!

When I arrived home, I decided to go through my old albums.  This is a collection that I assembled since I began listening to music in earnest in the early 1980’s.   I decided to listen to Houses of the Holy by Led Zeppelin.  One of my favorite tracks on this album is “The Song Remains the Same”.  I have listened to this album and song hundreds if not thousands of times since I first purchased it in 1984.  However, this time around – it resonated as it never had before.  As I contemplated the rationale behind this, the answer became very clear.


This past weekend marked the three year anniversary of Compliance Risk Concepts (“CRC”).  As CRC’s founder and managing partner, achieving this milestone conjures up great pride and a strong sense of satisfaction.  It also causes me to pause and reflect on the strategic vision I initially had for CRC – and question if The Song Remains the Same”?

Recipe for Success?

By way of background, I am a career Financial Services Compliance Officer.   I spent 20 years working for Investment Banks, Broker-Dealers and Asset Managers and other Integrated Financial Services Organizations.   Twelve of those years was as a Chief Compliance Officer (“CCO”).

Prior to launching CRC, I developed a business model aimed at changing the manner in which Compliance Professional Services were delivered within the financial services industry.  In essence, I sought to “reverse engineer” the system.

You may ask what this actually means.   Well, as a buyer of Compliance Professional Services for a good portion of my career, I had been “Big 4’d” to the point where I felt truly disenchanted.   I had a significant amount of first hand experience with failed engagements with Big 4 firm that either yielded no results – or lofty and unrealistic recommendations that were not practical – thus, never implemented.    All that was achieved was wasted time, efforts and resources.

Firms can no longer tolerate nor afford a model where they pay a senior partner $700 per hour for an engagement that is executed by individuals with little or no relevant experience at $200-$300 per hour.  It’s a strategy aimed at racking up billable hours – where the Consultant wins – and the Client loses.     The goal for CRC was to chip away at this model through one operating premise: Develop long term strategic relationships based on short term incremental and cost effective wins.   Bottom line: Deliver practical and achievable outcomes for our clients.

The “George Constanza” Method.

So – how was CRC going to compete and succeed in a highly commoditized vertical?   This is where the strategic vision came into play.   The approach was going to be honest, straight-forward, with one clear objective: EXECUTION.

Since I had been to this dance before, I knew exactly what I didn’t want to do.   I didn’t want to speak in catch-phrases and jargon – and in the end rack up a ton of billable hours and ultimately deliver nothing of substance or value.   Seinfeld fans will understand this next reference.   I call this the “George Costanza” method.   -  Do the opposite of what one normally does – and you will succeed!

I wish it were that simple.   Having said that, the operating premise holds true.   Isn’t the definition of insanity doing the same thing over and over expecting different results?  So, at the end of the day – for CRC to be successful, we would have to become recognized as an industry leader that distinguished itself by offering a service level that was predicated on a value proposition that actually delivered beneficial and measurable results to our clients.

What’s Our Belief System?

As a company early in its evolution, we needed to quickly establish our “belief system”.   What was our organizational DNA?  If somebody were to ask me the “Top 5” things we’ve embraced as a company, I would list the following:

  1. Truly “know” our clients. It’s critical to establish a vested interest in our clients’ outcomes.  This must go above and beyond any single engagement.  We are building a relationships.  Always looking at things with a long term view.
  2. Surround ourselves with talent. The reason CRC has grown and continues to grow is based on our ability to retain quality individuals with an average industry tenure of 15-20 years of relevant experience as CCOs or MD Level Compliance Officers that deliver consistently with superior service.  We do not “settle” when it comes to human capital.   Our success is predicated on our team’s success.
  3. Be thought leaders and decision makers. Our clients are hiring us for a reason.   They need our leadership and direction.   They didn’t hire us to merely reiterate the problem they knew they already had.    It’s our job to move the ball down the field – and get the client to an end result.
  4. Do what we love / love what we do.  Be passionate and show our willingness to have skin in the game.   It resonates and inspires trust and confidence.   We demand this in all of our employees – and won’t settle for less.
  5. Work with great vendor partners. Our clients constantly look to us for recommendations regarding technology vendors that can help assist in the execution of their compliance programs.   CRC has developed great relationships with several vendor partners that deliver functionality to our clients in a cost effective and efficient manner.   We work with vendors that can provide technology functionality to those who have historically priced out of such solutions – and never take a “one-size-fits-all” approach.

What Should Clients Demand?

Over the past few years, we have witnessed some pretty interesting service / support models of other Compliance Consulting organizations.    Based on our findings and our understanding of regulatory expectations, firms engaging with Compliance Consulting Service providers should be aware / weary of the following:

  1. “Checkers Checking Checkers”. Before signing on the dotted line – please be sure you know / understand the level of expertise and support that will be dedicated to your organization.    Is there a revolving door?  Will you have a new consultant supporting you every week / month, etc.?   Also – has this person ever spent a material amount of time within a financial services organization similar to yours?    Don’t buy a “checklist”.   Demand true expertise.
  2. Template Policies and Procedures / WSPs. It may be initially attractive and inexpensive to buy an “out of the box” set up policies and procedures.   However, please understand that regulators know all the templates.    Your policies and procedures must be truly reflective of your business model and business practice – and indicate with great clarity the supervisory reviews undertaken (who, what, where, why and how often).
  3. Gold, Silver and Bronze Support Plans. You are not buying new windows or a subscription to satellite television.    Don’t be sucked into a level of support based on your willingness to pay additional money.     A good and reputable consulting firm will customize a program specific to your needs – and not look to add a bunch of “al a carte” services to beef up their bottom line.

Bringing it Home

As an entrepreneurial organization in its early stages, we’ve learned many things over the past three years.  Most importantly, we have seen that people do want to connect with something they believe in.   We enjoy some of the greatest client relationships anyone could ever hope for.  Our clients connect with us, largely in part because we take the time and energy to find ways to truly connect with them. We work to understand their needs and issues, leveraging our deep bench strength to create sustainable and scalable results time and time again.   After all, it’s one thing to win a piece of business.  It’s a completely different animal when it comes to fulfilling that business.

In closing, does the Song Remain the Same for CRC?   It absolutely does.    As we continue to grow as an organization – it is imperative that we stay true to our core values.  We are a boutique provider that will continue to embrace our strategic vision and business philosophy, distinguishing ourselves from our peers through the quality of our execution and the strength of relationships we build with all our clients and prospects.

I leave you with one final thought.  If you are contemplating engaging a Compliance Consulting firm for the first time – or switching from your existing provider, please consider what I’ve discussed above.  Surround yourself with best-in-class service providers that will spend every day proving themselves to you – earning your trust and respect – and never taking your business for granted.   This is something we should all think about and demand in all our dealings.

As 2016 kicks-off, I wish you all much happiness, health and success in the coming year.





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