For those multi banks w/employees in distant locations (in or out of state):

We're experimenting w/remote training to accomodate new employees who cannot travel to our central location for New Hire Orientation (and to cut travel expenses as well). This training is customized to train the new employee on the bank's internal BSA policy and procedures.

How are other banks with locations in different states accomplishing their BSA training? If you're utilizing remote
training, I would appreciate your feedback (pros/cons). Feel free to PM with your responses.

THANKS!

We use online training through the ABA with a supplemental handout addressing the items specific to our financial institution. We just had an exam by the OCC and they were fine with this type of training.

We rely heavily on online training for annual training. For new employee orientation, the BSA training is done by a designated trainer. As we've expanded to multiple states, this has meant having multiple trainers staffed at multiple locations.

From my experience, the face to face training is only as good as your trainer. The online training is generally very good--it is thorough but not overwhelmingly so. It is more effective with new employees. Seasoned employees tend to breeze through it, complete it together, etc to get out of reading everything.

We also utilize online training (via BAI) for the annual training for all employees. We have opened locations in another state but we're not at a point where we can have multiple trainers at multiple locations. As the BSA Officer, I conduct the BSA training at our New Hire Orientation sessions.

By offering remote training, it will eliminate travel expenses BUT if for some reason, the new employee is unable to participate in the remote training, the BSA training session will be recorded which at that point, my request is the training be completed by month-end. I will require an email from the employee as confirmation they've completed the recorded training. Of course, at this point, it's on the honor system (surely, a banker will be truthful about completing their BSA training, right?) This is a new venue for us, so that's why I'm asking for feedback.

The BSA session in the New Hire Orientation will primarily cover our bank's BSA/AML/CIP/OFAC poicy and procedures.

My concern is if our examiners (FDIC) will be okay with
remote, including recorded training.

Your regulator; i.e. the FDIC, will not have a problem with it, but there is no one who can guarantee you that an individual examiner might not like it. Call the EIC from your last BSA examination and go over your plans.

The true test of a training program is whether your people know what the law says and understand their own responsibilities to comply with it. Certainly, some types of training are more effective than others, but there is no particular type of training that is simply unacceptable.

I don't think you should worry...they will probably be fine with it. In fact, I think they may even use online training for their staff.

Ken is right though, the true test of training is whether your staff understand their responsibilities.

I will check w/our FDIC field office examiners on our remote training.

THANKS for the feedback!!!