'I want them to look at me as an ally.'

When Kathy M. Curtis returned to her bank from a vacation th.is month, a new job was waiting for her.

While she was hiking through national parks in Utah and Idaho, Century National Bank's Community Reinvestment Act officer was quitting. So CRA officer was added to Ms. Curtis's existing duties as the bank's compliance officer and loan administration manager.

So goes the life of a small-bank compliance officer. Curious about their daily grind, American Banker followed Ms. Curtis around for a day.

A one-woman compliance department, Ms. Curtis struggles every day to make Century National's 32 employees understand why they need to comply with regulations.

Century National has a single office in downtown Washington, D.C. With just $82 million in assets, Century competes with area banking giants by maintaining a small-town atmosphere.

Responsible for the three-person loan department, Ms. Curtis personally checks every loan before it's closed, meticulously making sure that everything is done according to regulation. On a home improvement loan, for example, she checks to make sure settlement charges are disclosed properly. On the same loan, she notices a document is missing that is required by Truth in Lending.

Attention to Little Things

"Regulators pay attention to all these little things, so we pay attention to them too," she said.

Unfortunately, she said, it's not easy to get bank employees to concentrate on compliance. Loan officers are focused on meeting sales goals, Ms. Curtis said. Filling out forms and working on compliance is seen as an impediment to making those goals, she said.

In order to combat that perception, Ms. Curtis tries to put a positive spin on rules. "You have to sell compliance," she said. "Tell people how it will help them."

Ms. Curtis asks Century's loan officers to think of compliance as a customer service. Telling customers what they are entitled to know about their loans is part of compliance, she said. It also helps avoid complaints about, for example, incorrect annual percentage rates.

Continuing Education

Constant education is important to Ms. Curtis, who has attended the American Bankers Association's graduate compliance school. "I'm always looking for ways to improve the program," she said.

She said she was surprised to hear at a recent ABA conference that some compliance officers have trouble getting their senior management to invest in training or support compliance. Ms. Curtis said Century's management backs her decisions.

"We have a hands-off management," she said. "It's up to me to do things without prodding or coaching."

Ms. Curtis' immediate boss, Paul P. Schaus, is helping her with what she feels is a compliance officer's biggest problem.

They are shifting responsibility for reprimanding employees who do not follow the rules to the bank's audit staff. With compliance now handling that role, employees shy away from asking her questions for fear they will get in trouble.

"He doesn't want people to be afraid of me, and there are people who are scared," she said. "I want them to look at me as an ally rather than the person who comes around to criticize."

It's hard to imagine Ms. Curtis yelling at anyone, or even getting mad, but she said she does.

The bank plans to highlight Ms. Curtis' role as a resource rather than a bad guy by writing specific compliance responsibilities into every employee's job description. The auditor will then check up on the work. That leaves more time for Ms. Curtis to read regulations and write procedures.

Ms. Curtis said she sees this shift as part of the natural evolution of the compliance officer.

Starting at Century in 1985 as an assistant loan officer, Ms. Curtis stepped up to compliance officer in 1990. She began her banking career in 1979 at a Berkeley, Calif., branch of Security Pacific. The entrepreneurial spirit of a small bank is what attracted her to Century.

"I like the feeling of making an impact," Ms. Curtis said. Her efforts went a lot further after the bank automated its loan documentation process five years ago.

The system Century bought, LaserPro from CFI Pro Services, Portland, Ore., was expensive for a small bank. But Ms. Curtis considers the software invaluable. The program works so well, she said, it's virtually impossible to violate a rule if you set the system up correctly.

Checking Her List

Ms. Curtis, 36, starts her day by consulting a to-do list in her enormous blue leather-bound planner.

The planner, given to every employee at the bank, is a symbol of the culture at Century. "You can't be wasting time figuring out what needs to be done," she said.

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