In many ways the policies and procedures that make up your compliance program are analogous to the plumbing in your house. It is not something you typically spend much time thinking about, but if not designed for your specific requirements, professionally installed and quickly fixed when problems arise, you could literally be up to your neck in well, crap.
It is not all that different when it comes to your compliance policies and procedures. They need to be customized to the specific requirements of your company, maintained properly and updated when warranted by changes in your business, the composition of your customer-base or the regulatory landscape. And, like the plumbing in a new home, your policies and procedures must be installed at the very beginning of your company’s existence. Otherwise, they are always going to be a bad fit, work terribly and allow bad practices to seep into your corporate culture.