Compliance Champion or Slow Boiling frog?

The Just Noticeable Difference ("JND") is the smallest change in a stimulus that a person can detect 50% of the time. It's the scientific expression of the slow boiling frog problem.

This relates to the role of the chief compliance officer because running a business is dynamic. Every business feels like they are short on resources and time while maximally burdened with obligations. As a CCO to regulated entity your job is to make sure that no change to your business model or operations goes unnoticed and adequately addressed by your firm's compliance program.

In part, the solution is

  • Build a system that is simple, repeatable, and inspectable (the "SRI Model").

  • Never stop learning your compliance craft.

  • And stay organized by writing down even the smallest of changes to the business to ensure your carefully curated culture of compliance does not become the slow boiling frog.

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DEREO + BCT: A Framework for Regulatory Analysis