Meet "Lazy Larry" & "Detailed Debbie"

Having reviewed 1,000s of new client applications I am struck by two profiles of Sales staff that submit these applications on behalf of their prospective clients.

What Sales folks don't understand or appreciate is that they personally are part of the account opening review process. What I mean by that is that a good compliance professional assesses who in their organization is submitting the application in addition to the actual prospective client whose information is contained in the new account paperwork.

So let's take a look at these two Sales staff profiles.

"Lazy Larry" doesn't check the application material to make sure that it is complete and accurate. There is typically a combination of omissions and errors. Often these things are small but collectively they tell the compliance team that Larry didn't do a good job of checking everything before it was submitted. Larry is lazy. When this happens a small red flag is raised in the mind of the astute compliance officer. It's like Larry has come to bat and before he gets to the plate he already has one strike against him. These omissions and errors require unnecessary and time consuming back-and-forth between Larry, the compliance team, and often the prospective client (who unfailingly finds this bothersome). The deeper nagging question that a good compliance officer thinks about is what else might have Larry done incorrectly or omitted? If Larry can't be bothered to submit an accurate and complete application is there something wrong with the prospective client? Everything may be perfectly fine but still the compliance professional wonders.

"Detailed Debbie" submits complete and accurate new account applications. As soon as the compliance officer sees an application submitted by Debbie they breath an unconscious sigh of relief. At least the compliance officer can start the review not worrying about basic material in the application. When Debbie comes to the plate she has no strikes against her and in fact she may even be awarded a sub-conscious extra 4th strike for historical good behavior. This isn't to say that there aren't potential problems with Debbie's prospective client. The compliance officer must still be vigilant and do a complete and objective review to assess the application. But Debbie's detailed groundwork makes the process smoother and more focused on what really matters - who the prospective client is, what the demonstrated need is for the proposed services, formation documents check out, and other background checks clear with flying colors.