1. Chief Compliance Officer
Valiants Verify
Compliance Program
Judith W. Spain, J.D.
Chief Compliance Officer

2. Overview Compliance Background
Elements of an Effective Compliance Program
Valiants Verify Compliance Program
Annual Compliance Risk Assessment
Next Steps
Questions

3. Compliance Background

4. Compliance is Not New
Laws and regulations are the same; always had to comply
Historically, compliance has been decentralized (silos) without Board of Trustees oversight
Compliance program provides assurance to the Trustees and College management regarding institutional compliance
Assists both groups fulfill their fiduciary responsibilities

5. Compliance Program Identify compliance risks
Raise awareness of compliance risk
Keep employees aware of current compliance risks
Implement management controls
Assist in developing policies and trainings

6. Elements of an Effective Compliance Program

7. U.S. Federal Sentencing Guidelines
To have an effective compliance program, an organization must establish and maintain an organizational culture that “encourages ethical conduct and a commitment to compliance with the law.”
U.S. Federal Sentencing Guidelines
§8B2.1(a)(2)

8. Elements of an Effective Compliance Program:
High level personnel who exercise effective oversight and have direct reporting authority to the governing body;
Periodic compliance risk assessments;
Written policies and procedures;
Training and education;

9. Elements of an Effective Compliance Program, cont’d
Lines of communication;
Well-publicized disciplinary guidelines;
Internal compliance monitoring; and
Response to detected offenses

10. Valiants Verify Compliance Program

11. Valiants Verify is…
Board of Trustees approved initiative that provides an infrastructure to facilitate on- going assurances that the College has methodologies in place to comply with laws, regulations, and policies.

12. Valiants Verify is NOT…
An enforcement mechanism
A “Big Brother” mode of “mind control”

13. Valiants Verify is… Commitment to:
“Since Manhattanville’s inception in 1841, its founders have bequeathed its mission, vision and heritage of social responsibility: the symbiotic relationship of academic excellence and social and ethical responsibility to its faculty and students.”

14. Purpose of Valiants Verify
Identify compliance risks that impact the College.
Understand the potential exposures of the compliance risks and ensure we have measures in place to proactively mitigate those exposures.
Foster a culture of ethics and compliance that is central to all of the institution’s operations and activities.
Provide a resource to those charged with day-to-day compliance activities.

15. Program Structure Compliance Partners Chief Compliance Officer
President’s Cabinet
President
Board of Trustees Audit Committee

16. Compliance Partners
Responsible for day-to-day compliance activities (not necessarily the area VP);
Develop and execute quality, effective training programs to mitigate compliance risks;
Complete compliance risk self-assessment surveys; and
Assist CCO in identifying level of probability and potential impact of occurrence.

17. Chief Compliance Officer
Manage a compliance risk assessment;
Rank compliance risks on probability and potential impact of occurrence;
Develop an annual plan of risk areas to be addressed;
Submit the compliance monitoring plan to the President’s Cabinet for approval; and
Work with the Compliance Partners to develop policies and trainings, as necessary.

18. President’s Cabinet
Assist the Chief Compliance Officer in monitoring of the University's compliance with legal and regulatory requirements;
Review the College’s compliance risk assessments, identify areas of highest compliance risk, and propose activities and programs to effectively manage those risks;
Seek any information it requires from College employees or external parties; and
Recommend appropriate actions to the President.

19. President
Provide tone at the top for implementation of the Valiants Verify initiative;
Review recommended appropriate actions provided by the President’s Cabinet;
Exercise effective and ongoing oversight of the compliance program;
Approve the compliance risk mitigation plan; and
Inform the Board of Trustees Audit Committee of any significant compliance issues.

20. Trustee Audit Committee
Ensure that the proper tone for compliance and ethics is established and reinforced;
Be knowledgeable about the Valiants Verify program;
Exercise effective and ongoing oversight of the compliance program; and
Inform the Board of any significant compliance issues.

21. Annual Compliance Risk Assessment

22. Purpose of Annual Compliance Risk Assessment
To maximize the use of the College’s limited resources by directing them to the most significant compliance issues.

23. Risk Assessment Process
Step 1: Compliance Risk Identification
What are the possible compliance risks Manhattanville College faces?
What issues keep us up at night?
Create a compliance risk registry
Utilizing existing risk registries with customization for state compliance risks

24. Risk Assessment Process
Step 2: Compliance Partner Identification
Who is responsible for the day-to-day compliance activities for identified risk?
Examples of compliance risks
Truth in Lending Act
OSHA
Consumer Credit Protection Act
Examples of Compliance Partners
Voter Registration – Dean of Students
Title IX – VP for Student Affairs
Clery Act - Director, Department of Campus Safety
Financial Aid - Director of Financial Aid & Veteran's Affairs

25. Risk Assessment Process
Step 3: Self-Assessment Survey
CCO sends self-assessment surveys to identified Compliance Partners
Compliance Partners provide information regarding existing and needed methodologies for compliance
Policies, procedures, trainings, staffing, etc.
Compliance Partners return surveys to CCO

26. Risk Assessment Process
Step 4: Perform Risk Assessment
CCO reviews the self-assessment surveys
Compliance Partners and CCO together rank the likelihood of the compliance risk event happening and the potential impact of the compliance risk event

27. Risk Assessment Process
Step 5: Develop a Monitoring Plan
Developed by the CCO for the high probability and high impact compliance risks
What steps must be taken to mitigate the compliance risks?
What policies and/or trainings need to be developed?
President’s Cabinet reviews and makes recommendations to President to approve the compliance risk monitoring plan

28. Risk Assessment Process
Step 6: Implement the Monitoring Plan
The CCO works with the Compliance Partners to implement the approved compliance risk monitoring plan.

29. Next Steps

30. TENTATIVE Timeline
Identification of Compliance Partners – Dec. 2015/Jan. 2016
Informational sessions with Compliance Partners – Jan./Feb./March 2016
Implementation of self-assessment survey
Sent to Compliance Partners – March/April 2016

31. TENTATIVE Timeline 2015-2016 Self-assessment survey results
CCO completes initial risk monitoring plan – May 2016
Present compliance risk monitoring plan to President’s Cabinet – June/July 2016
Implementation of compliance monitoring plan – Fall 2016

32. Project List Valiants Verify webpage
Develop “Whom Do I Call If?” matrix
Develop Compliance Calendar
Conduct Compliance Awareness and Effectiveness Survey
Implement policy webpage/policy review

33. Associations with Reference Materials
NACUA:
Society for Corporate Compliance and Ethics:
Association of Corporate Counsel:
ECOA:
NACUBO:
Higher Education Compliance Alliance:

34. Questions?