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Question & Answer
Question: How often should a bank conduct compliance training?
Answer: As to explicit requirements, only two laws - BSA and Funds Availability - specifically require employee training. In addition, the old CRA regulation included consideration of the bank's fair lending training although neither ECOA nor the Fair Housing Act contain training requirements.
That's the explicit requirement. However, as a general rule, you should conduct compliance training for affected bank staff on each regulation or regulatory requirement on an annual basis. This doesn't mean that everyone has to have the entire basic course every year. But memories aren't perfect. For example, how much do you remember - without referring to your notes or listening to tapes - from last year's conference? It's simply a good idea to give refreshers on a regular basis.
Training need not always be formal. You can often refresh and retrain effectively simply by discussing the regulation in a staff meeting. Drive home the points by discussing a specific situation - preferably one that is on someone's desk at the time. People can be more willing to come to this kind of meeting than to attend "training." And they may go out learning more.
Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 5, 4/97
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