Collaborating Author: Ina Thompson
Recently I said to a friend, “Man, I am sick and tired of this cold weather. How cool would it be to hop on a plane and head to the beach?” I was a bit shocked when my friend replied, “Let’s do it! Let’s be crazy and book a trip today! What are you thinking? Miami? Mexico? Puerto Rico?” Quickly, reality set in as I started thinking through all of the logistics of quickly planning a vacation – how much would it all cost, who is going with us, how do we get there, where do we stay?
In my last blog post, I shared 10 tips on how to fast track your 504 preparations. In this blog post, I am going to share details to help you successfully plan your 504 project and show you how similar it is to planning a beach getaway. Vacations, even the spontaneous ones, still require planning to be successful…the same applies to your 504 project. So, let’s start planning this “vacation”!
When you plan a vacation, you don’t always know the exact cost – there are always extra (and unexpected) expenses - the same is true with 504 planning. However, there are known elements that you can budget for. Think of these like booking a flight, hotel or rental car:
- An independent review and model validation – This can be performed by either an external third party or internal audit (provided they have the required skill and knowledge base). Budget estimates can be leveraged from historical third party engagements. The vendor selection process will play the role of Expedia, allowing you to compare options and refine your budget.
- Subject matter expert time and contribution – These are your people that are currently responsible for part or all of the transaction monitoring and filtering programs (consider all impacted functions: compliance, IT and operations). The total cost will be the time required multiplied by the daily rate.
- Project management – Part 504 involves multiple stakeholders, 21 individual requirements, independent end-to-end program review, cross-function (and possibly cross-border) coordination and a hard deadline, which means a rigorous project management process is critical. You may have an internal PMO group or you may leverage external help for managing large projects. In either case, the budget for project management will be the total time required (likely to be majority of the project) multiplied by the rate.
This is the time to account for the known costs. A little planning now will save a lot of wallet ache later.
A key to a great vacation is having the right mix of friends and family with you to enjoy it. For your 504 project, you need the right staff to go on the journey with you. These will be the people who will be guiding the project and ultimately certifying your programs.
Part 504 requires that you have dedicated, skilled resources involved in the development, implementation, monitoring and governance of your Transaction Monitoring and Filtering Programs. During the budget process, you need to assess which resources are available for your 504 project. Ask yourself, “Do I currently have available and qualified resources to support my 504 project? Do they have the capacity to take on the additional workload?” If the answer is no, it’s time to start looking. Don’t wait until the end of 2017 to discover you need help.
When planning a vacation, you like to choose reputable hotels and airlines. Although you aren’t spending your vacation with the hotel staff or the flight attendants, they do play a key part in making sure your vacation is enjoyable. The same holds true for your project stakeholders – you need to make sure you have the right stakeholders involved. Key stakeholders should, at a minimum, include representatives from Compliance, Operations and IT. Take the time to educate all of your stakeholders on 504: what it is, who it impacts and why it’s important to them and the company as a whole. Cooperation and coordination across the company is important and key to an accurate and punctual certification come April 2018.
Once you decided on the destination for your beach getaway, you can finally get excited about booking and planning the trip - who doesn’t love a good agenda on their relaxing beach holiday?
A few things to consider as you build your 504 plan through April 15, 2018:
- Certification Deliverables - identify what documents you need to demonstrate that you are in compliance with all 21 Part 504 requirements and whether these deliverables currently exist.
- Independent Review - build in time for the vendor selection process, the review and adequate time to remediate gaps identified. Scheduling your review for Q4 2017 is not going to impress your colleagues, those signing the certification or the DFS!
- Certification Protocol - similar to the Sarbanes-Oxley annual certification process, creating a framework that will make a senior executive comfortable with certification will take time. A documented certification framework should be developed prior to beginning the process.
Once you have created your high level plan, you can start getting more into the details of the plan: milestones, dependencies, risks/delays. Do this planning early so that one delay doesn’t halt your entire project.