QUESTION
We need an overhaul of our policies and procedures. Our company merged with another company, and our policies are different in many ways, from the text itself to the format. It is tough enough to have the merging of two cultures, we are now banging into one another over what policy applies and what procedures to follow.
As the Compliance Officer and General Counsel, I am involved in harmonizing these documents, and the task is almost overwhelming. Every project impacts our policies. We have had to update our Change Management policy five times in the last six months just to adapt to the merging of documents.
What I need is some kind of checklist that I can get stakeholders to agree to or at least accept by consensus. I consulted with experts in policy development, but it was frustrating. If they knew the regulatory requirements, they disagreed on the text, and if they knew the formatting requirements, they disagreed on the best format. They seem oblivious to the implications of Change Management.
A member of our Board of Directors referred me to you. She believes you can help resolve these issues. So, I'm writing you for guidance. I also want to schedule a call with you to discuss your services.
Can you help us understand how our policies and procedures are linked to our Change Management requirements?
SOLUTIONS
RESPONSE
There are a few aspects to your circumstances. Not only do you mention the issue of merging policies and procedures resulting from a merger and the impact on projects, but you also note how many times you have had to update your Change Management requirements because of this debacle. We have handled and resolved matters such as yours many times. Your situation often happens.
Many clients come to us for our customized compliance library. Since you are new to our services, it is worth knowing that we pioneered the effective drafting and implementation of a compliance library. So, you have come to the right place! I'm sure we can help!
Let's start with Change Management. What is it? Essentially, it is the governing methodology that provides an infrastructure to support and sustain change throughout multiple phases in your financial institution while focusing on achieving a set of defined and desired business results.
There is a good reason why you mention Change Management. That is because your policies and procedures are an intrinsic part of it.
To clarify, a financial institution is under pressure from regulators, borrowers, shareholders, and investors to improve its business continuously. These pressures lead to companies initiating a wide range of company projects, including small, targeted updates, process enhancements, large, complex system implementations, and major business process re-engineering initiatives. Thus, an institution's ability to standardize its process and project management practices mitigates the risk of project failures and maximizes the value delivered to its organizational processes.
Therefore, you have hit on the two primary purposes of Change Management:
· Process Management, and
· Project Management.
I am going to offer a way to think about Process Management and Project Management and how they link to Change Management. Merged policies and procedures will be given their due consideration.
BUILDING A CHANGE MANAGEMENT FRAMEWORK
Before understanding the operational
framework of Change Management, its two primary purposes, and its derivative
structures, such as policies and procedures, you must determine:
1. Define and describe what changes will be implemented.
2. How to coordinate the input from stakeholders.
3. What will constitute a formal change plan.
4. The resources and data that will be used and available.
5. The overall communication strategy at all operational levels.
6. A review of budget risks associated with change.
CHANGE MANAGEMENT METHODOLOGY
As the company's Compliance Officer, it would be your responsibility to establish controls to ensure a viable Change Management methodology is applied consistently between individuals and work groups.
I recommend that your methodology contain the following guidelines.
· Determination of business ownership and governance responsibilities.
· An impact analysis prior to the implementation of process changes.
· Communication of new or revised processes to impacted business units or areas.
· A process that ensures policies, procedures, and processes are updated to reflect remediated control deficiencies.
