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Foreclosure Crisis Highlights the Need for Document Policy Enforcement

My last two posts talked about how politics are a rich source of document-policy lessons, but a discussion at the ECM course I taught last week centered on the need to stress policy enforcement as well! So keeping to our political theme this election week, let’s take care of that right away.

The recent crisis in home foreclosures is nothing but a failure to enforce, and all kinds of mayhem is being unleashed on owners, buyers, sellers, and even the banks because their people apparently weren’t actually reading their documents of destruction! I have no doubt their policy manuals say they’re supposed to read the stuff, but without anyone apparently checking to be sure it’s happening, people are being tossed from their homes and sales are being delayed or disrupted.

This is a (sub)prime example of how having the best policies in the world means nothing if you don’t have any enforcement – or at the very least, any credible threat of enforcement. Take the IRS, for instance – it actually audits a very small percentage of taxpayers, but it achieves a high level of compliance because people just know that they will be caught and punished if they don’t follow the rules.

Wanted: Compliance Whisperer
Now, I’m not suggesting you develop the same heavy-handed persona the IRS has to ensure your people properly protect and manage the information they deal with. But you do want to make it clear that you’re not kidding when it comes to doing the right thing.

In most cases, the trail to compliance begins and ends with a talking-to: the new system or process is turned on, and people are told “you will use it, you will like it, or you will pay the price.” Not surprisingly, the typical response to this is “yeah, right” and business goes on as usual.

My suggestion is that you take a lighter approach to delivering the message – any good horse whisperer, after all, will tell you that the key to behavior modification isn’t loud threats of reprisal – or worse, actual reprisal – but rather promises (and delivery) of rewards!

Lessons Learned
So it is with compliance as well – yes, outline the critical importance of the thing, and stress that there are consequences for activities gone wrong. But then try to catch people doing something right, not wrong, and see how far you can get!

Have contests for ‘most documents tagged’ or some such – with points for quality, not quantity, of course … give away T-shirts or coffee mugs for process improvement ideas used. Make it fun, get people to think of it as being within their control, and they will climb on board!

But also make it known that compliance is a big part of the grade at performance review time, so even the more reticent – or sloppy – of folks know they’re not off the hook.

No more so than so many of today’s mortgage bankers.

Links to look at
Flawed Foreclosure Documents Thwart Home Sales; New York Times; October 7, 2010

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