Your team is in place. You've established your context. You are now ready to begin producing your Plan.
The collective goal here is to promptly generate a thoughtful and close-to-final draft Plan.
Step 3: Produce
Focus first on your audience(s). Management is one audience. And the team should also factor in that the Plan will be reviewed by regulators in the event of an inquiry or investigation. Persons implementing parts of the Plan may also need to review the actual document as they do their part. Get team input on other possible viewers of the document.
Circulate your outline to the group. Begin the process of making your outline of the group’s Plan:
- Are your original ideas clear and understood by those not familiar with compliance terms and methodologies?
- Are all the variables covered? (See third paragraph above.)
- What’s missing, and where should the missing pieces go?
- Assuming that the Chief Compliance Officer (CCO) will lead the primary drafting element, who wants (and is qualified) to draft various sections (or will the time and degree of explanation required actually slow the process down too much?)
- What’s the best form for the document? (Stay away from the all text legal brief format so disliked by non-lawyers.)
- What’s a realistic time frame for pulling everything together, and what interim reviews and group meetings are required to reach that goal?
Once the draft is complete, and you’ve thoroughly reviewed it for clarity, accuracy, consistency with corporate cultural considerations, and explicit support for business goals, take the Plan draft “on the road.” Consult with those “sounding boards” not already in the group. Perhaps there are trusted compliance contacts at other companies that could give you a “fresh eye” Plan review and offer their own comments. Give summary overviews to management, touching on those specific parts of the Plan that will be of most interest to them, and solicit their reactions and comments.
After processing the input of these various parties, and with a final review with the group, present the now final group Plan to the necessary parties and/or to those optional roles or departments that you want to inform about the Plan. Emphasize the collective, cross-departmental nature of the group that produced the Plan, and its business focus.
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