Covering Required Training Subjects
by John Burnett Guru BIOS
There are five areas where law or regulation mandates training for bank employees:
Expedited Funds Availability (Reg. CC);
Bank Protection Act (physical bank security);
Anti-money laundering (Bank Secrecy Act);
Customer Identification Program requirements (CIP rules);
Information Security (Interagency Guidelines for Safeguarding Customer Information).
As we recommended in a previous article on required training subjects, start with the five most important concepts for the topic being discussed, and build on that list. Be sure to customize the training to reflect your institution's own philosophy, procedures and terminology. Develop testing or other feedback mechanism to ensure that each employee understands the basic principals. And we'll add here, be certain to document the content of your training, your training measurements, and attendance.
Mary Beth's previous article covered four of the five mandated training topics. In this issue, we'll discuss five key concepts for Regulation CC training.
Your institution's availability policy should be the focus of attention. It profits no one to discuss the limits in the regulation, except to know they are there. Your people need to know your policy.
Make sure you define the concepts of local and non-local checks carefully. If you have different local check definitions for some of your branches, make your people aware that one customer might receive different information about the same check's availability depending on where he deposits it. Don't forget to update this information after formal training occurs if consolidation of Federal Reserve check processing centers affects your definition of local checks.
Be clear about next-day items, and spend extra time discussing the challenges presented by phony cashier's or teller's checks. Make sure your bank has a policy for dealing with questionable cashier's or teller's checks, and train to that policy.
Explain your bank's policy about invoking case-by-case and exception holds. Be certain you cover the proper method for completing and delivering hold notices. If you restrict the authority to place exception holds to supervisors, be sure to explain that policy.
Cover the alternative of using collection when a questionable check is received for deposit. Reg. CC doesn't require that you accept any check for deposit; it covers what happens when you do. Discuss any policy on contacting drawee banks for check verification before deposits are processed. Make it very clear that a bank's refusal to verify a check is not the same as saying the check isn't collectible, and inability to verify is not a valid reason for an exception hold.
It's clear that there is a lot of information that needs to be included in your training sessions for Regulation CC. Here's one more key piece of advice: Make sure you understand all of the fine points of your bank's availability policy and procedures before you attempt to pull together your material for the first training session.
The original version appeared in the August/September 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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