Companies
Executives and board members in financial services are increasingly held accountable for the actions of their firms. Among their many responsibilities, they are required in particular to be engaged in their company’s efforts to adhere to the letter and spirit of laws that seek to ensure consumer protection.
As the regulatory landscape facing executives in the financial services industry has grown increasingly complex – and integral to their enterprises and their firms’ reputations – so too has the need to demonstrate and document the actions taken by their firms.
Gate House Chairman and Partner Brian Montgomery recently outlined the challenges facing executives in a piece for HousingWire. As he argued, even with the best of intentions, there are often inconsistencies and conflicting interpretations of what firms need or ought to do — and what executives need or ought to in order to stay apprised of their firm’s efforts. One thing we know it that it will require vigilance and a lot of hard work to get it right.
Recognizing the important need in C-suites and executive board rooms, Gate House Strategies has launched a new subsidiary, Gate House Compliance, LLC, to provide fair lending and compliance management services. The firm, comprised of veterans in financial services and specialists in fair lending and consumer protection law and regulation (and support from CrossCheck Compliance’s deep bench of experts), will advise and support compliance regimes across multiple asset classes, including mortgage, student loan, credit card, and other secured and unsecured credit products.
The addition of Gate House Compliance is a timely and critical expansion of the firm’s ability to serve the growing needs of the industry. After careful examination, clients can choose services that complement their current compliance program, or on a subscription basis, they may utilize Gate House Compliance 365, a comprehensive system of ongoing support of fundamental services and a coordinated, dynamic approach to the management of regulatory risk.
The important policy goals our country require executives to be engaged. They need experience, perspective, and insight in order to do what is right and, and – when the path is made unclear by conflicting policies or interpretations – what is prudent for business.
The goal for Gate House Compliance is to put executives and firms ahead of the curve and ahead of the scrutiny that characterizes the current environment and road ahead. Vigilance and a team of experts with a steady hand will be a must.
Gate House Partner and Chairman Brian Montgomery shared his perspective on the regulatory landscape facing executives in the financial service industry — the need to act responsibly with respect to fair lending laws and to understand the complexity of it all – in a piece for Housing Wire.
“[M]ultiple agencies pursuing the same general goals sometimes creates inconsistencies or conflicting interpretations of policy, making it difficult for financial institutions to navigate uncharted waters, even with the best of intentions.” Montgomery wrote.
Montgomery, who served as Deputy Secretary of HUD and FHA Commissioner twice, emphasized the risks, particularly in the areas of lending and loan servicing: “Recent regulatory actions have targeted marketing practices, credit allocation and product offerings,” he said, with top executives more often being held accountable for their “company policies, procedures, operations, and culture.”
With risk to the firm not only financially but reputationally, the need to “identify gaps that may exist in their knowledge and experience and structure management teams accordingly” is paramount if they are to demonstrate to overseers that they possess a comprehensive approach to their compliance obligations.
Private industry participants have their work cut out for them as they go about the critical work of upholding the letter and spirit of our country’s fair lending laws, Montgomery said. Both private firms and government must work together at times, with private industry willing to serve as partners to government and the government for their part providing “transparency, open dialogue and technology improvements” to make our system work.
Happy Friday. After completing a remarkable first two weeks for Gate House Strategies, I wanted to take this opportunity to thank everyone with whom we’ve had the pleasure of engaging and many others who have been in touch.
Already, the firm has forged meaningful partnerships with longtime colleagues in the housing market and beyond, rekindled relationships that we believe will help the industry resolve critical and timely policy challenges (some age-old and others arising out of the pandemic), and been contacted by numerous others whose unique goals and enterprises portend well for future relationships with our firm.
We are hard at work discovering paths forward, finding new avenues for success – merging the unique expertise and perspective within the industry with our knowledge, experience, and relationships, forming coalitions of key allies, and leveraging it all to achieve results.
Now while that’s a mouthful after just two-and-a-half weeks, as we tried to convey at the launch we are on a mission to assist our clients’ efforts to build, to innovate, and to grow — to add to the long tradition and commitment to a strong and vibrant financial services and housing market that serves the interest of all Americans.
A few days after announcing this venture, I was on a plane to Jacksonville, FL to attend the Mortgage Bankers Association of Georgia (MBAG) annual conference, the first in-person event I have attended in over 14 months and one rescheduled twice last year (and I suspect the same for the other attendees).
Suffice it to say we were all incredibly excited to come together once again like real, non-virtual people, to see one another, and to begin to share ideas again amidst a sure sign that things are starting to get back to normal. The excitement was palpable and it warmed the heart to see close friends and colleagues see each other face-to-face for the first time in many, many months.
The next morning, Rob Chrisman and I conducted a panel together, and we could feel the readiness to look ahead and to build upon what was an extraordinary year in housing. Just before we walked on stage Rob turned to me and whispered, “I have the hiccups!”
Perhaps it was the perfect metaphor for involuntary, seemingly inexplicable contractions of the COVID-19 era that require creative, innovative solutions in front of a live audience.
Without missing a beat, our moderator (upon hearing a hiccup) declared she had a sure-fire cure that never fails. She rose up and walked over to Rob imploring him to stand up and raise his arms high above his head. She asked for a glass of water but saw one on the podium (Note: it was mine from the previous session which I did sip from (sorry Rob)). The moderator then held the glass and told Rob to tilt his head back and keep drinking but to wave his hands when he had enough. I immediately thought of waterboarding but Rob kept chugging before giving the audience his version of “jazz hands.” And it worked much to the audiences laughter!
We had a great session and can’t wait to do it again soon. (And thank you, Rob, for the shout-out on your unmatched-in-influence blog about Gate House as “the new kid on the block.”)
But getting back to business, we are hearing from a lot of people, new and old, who are seeing the challenges we are seeing and who are looking for the best solutions, working to position themselves to both take advantage of new opportunities this year has in store and looking beyond the pandemic to strategies that will achieve the mission.
Again, we are looking forward to it all and can’t wait to help our partners navigate this journey ahead.
–Brian Montgomery, Chairman and Founding Partner, Gate House Strategies