Virginia Regulatory Town Hall
Agency
Department of Criminal Justice Services
 
Board
Department of Criminal Justice Services
 
chapter
Regulations Relating to Private Security Services [6 VAC 20 ‑ 171]
Action Comprehensive Review Private Security Services Regulations
Stage Proposed
Comment Period Ended on 6/10/2010
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4/2/10  5:30 pm
Commenter: Wayne Boggs, Richmond Alarm Company

6VAC20-171-240 Compliance Agent
 

We are still allowed to only represent one licensed entity as a Compliance Agent.  There are many arguments for allowing one to represent multiple firms, and I think very few against.  In favor of allowing an Agent to represent multiple firms:

Small Companies have difficulty with maintaining the training and registration requirements of all their employees, particular owner operators, and this is an added burden. 

These same owner operators seldom understand all the requirements or the regulations, and must consult others for advice on a regular basis anyway.  DCJS, though available, is not the easiest to contact, and their answers are frequently couched in language that the small businessman simply does not follow.  An experienced Compliance Agent could develop a much closer relationship with the firm he or she represented and more easily answer their concerns.

I firmly believe part of the lack of compliance by particularly small firms is both a lack of understanding and a disregard for the ramifications of the regulations.  Working with an experienced individual Compliance Agent would be like working with an Accountant or Attorney.  The advice would be readily accessible and valuable.

Finally, such a Compliance Agent would be very motivated to assure compliance by those he or she represented.  In today's environment of lax investigation, audit, and compliance administration, these Group Compliance Agents would increase the number of trained and highly motivated individuals making sure licensed companies understand the regulations and operate fully within the law and regulation.

Against allowing Compliance Agents to represent multiple enties:

Sorry, I can't think of any defensible ones.

CommentID: 13738