Five Simple Ways to Stay Compliant in Financial Services

Jodi Golinsky has worked in financial services for nearly fifteen years, and here she shares a few of the guidelines she follows to promote both compliance and growth at her latest company, FS Card

Jodi Golinsky

Jodi Golinsky’s interest in financial services started at a young age. During childhood, “both my parents were very focused on teaching me about finances and how important it is to manage your finances,” Golinsky says. “I opened up a savings account at my local bank as soon as I was allowed to.”

Given her longstanding interest in financial services, perhaps it’s no surprise that Golinsky worked with some of the biggest names in the sector, including MasterCard and American Express. Today, she serves as general counsel and chief compliance officer for FS Card, which helps underserved consumers manage short-term cash-flow needs. In addition to her work at FS Card, Golinsky offers input on portfolio-company opportunities and business models for Fenway Summer Ventures, a venture-capital firm associated with FS Card’s seed-capital provider, Fenway Summer, LLC.

To excel in her role, Golinsky champions compliance initiatives while balancing company growth and innovation. In her view, sound compliance leadership is a direct contributor to sustained growth and innovation in the business. In her observation, there are three primary compliance issues companies face in the financial-services sector: searching for clarity surrounding regulations, keeping eyes and ears trained on a changing regulatory landscape, and ensuring a level playing field for all organizations in the sector.

Over the years, she’s developed particular methods for managing these issues effectively, and in a conversation with Modern Counsel, she shared five best practices other financial-services attorneys can follow to improve their chances for success.

1) Participate in Decision-Making

“Sometimes people view lawyers as silos away from the business itself, where attorneys go research things alone and then come back with answers to questions,” Golinsky says. She challenges that misconception by sharing her methods and thought processes with colleagues outside the legal department and having a seat at the table alongside her business partners whenever she can.

Board meetings are just one occasion for such sharing and transparency. “When the board asks me direct questions about a recent ruling or regulatory development and how it impacts us, I answer the question head-on; I’m always incredibly honest and very transparent,” Golinsky says. She shares her knowledge without sugarcoating the facts.

The regulatory landscape for unsecured credit cards is incredibly complex, with both federal and state laws and regulations impacting the way in which credit can be offered. Golinsky keeps her board and her company apprised of all the latest changes, from court rulings to new regulations. The Consumer Financial Protection Bureau’s recent payday rule is an example. Within hours of the rule’s release, Golinsky had shared her viewpoint about the its likely impact.

2) Be an Action-Oriented Listener

If legal issues were entirely black and white, then companies wouldn’t need in-house counsel, Golinsky says. She and others on her legal team resolve ambiguities by meeting with businesspeople from other departments and exhaustively raising all issues. In this way, the two sides learn from one another and approach issues from myriad angles.

Golinsky also reports directly to FS Card’s CEO, and the two meet often. She always appreciates the chance to hear another person’s point of view on the challenges the company faces. “People like to talk and know they are being heard, so learning how to listen is a really important skill,” she says. Give and take is what makes for getting the best results for the business and the legal team. “I think both are practiced here, at the highest level—in our board meetings—and day to day,” Golinsky adds.

3) Weave in Opportunities for Training

“You can’t expect people to know certain things are okay or not okay if they’ve never been given the right training to know the difference,” Golinsky says. “We have a very robust compliance and training program that I developed from the ground up.”

Golinsky’s legal team trains employees both during onboarding and on an ongoing basis. The ongoing lessons are more vital, Golinsky says, because the information is most relevant when employees are fully engaged in their work.

“We have lunch together every Wednesday as a company,” she says. “On those Wednesdays, I try to have my team do some form of compliance training.” The training covers not only the company’s existing compliance policies and procedures but also topics such as new regulations, best practices, and attorney-client privilege. In her experience, the businesspeople outside the legal department retain the information well.

4) Make Yourself Available to Respond Quickly

Attorneys should reply to communications promptly, Golinsky says, to send the message that their colleagues can rely on them. “I may not always have whatever answer you need, but I will always get back to you in well under twenty-four hours, even if it’s just to say, ‘I am looking at this and will get back to you soon,’” she says. “The same-day response is a standard I hold myself and my team to; it’s a standard that’s worked for me.” To be a trusted advisor and partner, you need to be available.

5) Elevate Others

When Golinsky sees her colleagues—inside or outside the legal team—doing excellent work, she doesn’t keep it to herself. Instead, she commends them and alerts their superiors and the company’s CEO to their successes. “I know that the people who work with me are helping me, helping our company, and making us look good every day,” Golinsky says. “I am grateful for that. I make sure that they know that because it matters.”