As we near the end of 2018, it is time once again to build training calendars for the upcoming year, and decisions must be made on what topics to include. Two questions we are frequently asked by compliance officers as they begin making decisions on which courses to cover are, “What regulations have required training, and how often must staff be trained?”
To help financial institutions get started, below is a list of the regulations with training requirements:
- The Bank Protection Act stipulates that management should provide initial and periodic training to employees on their responsibilities under the security program and on proper employee conduct during and after a robbery.
- One of the pillars of the Bank Secrecy Act is training of appropriate personnel. The FFIEC’s Bank Secrecy Act/Anti-Money Laundering Examination Manual details the training expectations for personnel, including the Board of Directors. The details can be found here: https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_007.htm.
In addition, within the Customer Identification Program (CIP) examination procedures, examiners are instructed to evaluate audit and training programs to ensure these requirements are adequately incorporated.
- Privacy of Consumer Financial Information, Regulation P, also does not contain a specific requirement for training, but the Interagency Examination Procedures instruct examiners to determine the adequacy and regularity of an institution’s training program. For violation(s) noted, examiners are to determine the cause by identifying weaknesses in internal controls, compliance review, training, management oversight, or other areas.
Although annually is not always specified as the timing interval for these trainings, this is typically what we see as an industry practice. We believe training should be as frequent and as detailed as is needed to keep employees fully informed of their responsibilities so they can provide the best consumer service possible while protecting the assets of the financial institution.
Whenever a financial institution recognizes a weakness in complying with a regulation’s requirements, training is generally one component of corrective action. Therefore, before deciding on what to include in the 2019 training calendar, we recommend reading through examination reports, internal and external audit reports, and reviewing monitoring logs to identify areas of concern where knowledge should be enhanced.
Also, check out the Bureau of Consumer Financial Protection’s Rulemaking Agenda to find out what’s on the horizon and ask marketing if any new products or services will be introduced. Armed with all this information, you will be prepared to develop an effective compliance training plan for staff.