According to Part 326.8(c)(4) of the FDIC Rules & Regs, management must provide BSA compliance training for "appropriate" personnel. I have determined our Facilities Department does not need BSA training, but what about proof operators or human resources? What employees, (if any) can be exempted from receiving BSA training?

Just to hit on your comments about proof operators - they're very likely to be the folks to see if tellers are processing their own transactions, many times they may notice unusual items in deposits!

In this current BSA enviornment, I am basically training everyone, but getting some resistance from certain employees (i.e. bank appraiser) who feel it's unnecessary since it doesn't apply to their job function.

It's so helpful when the reg just says "appropriate personnel" and then you're left open to examiner interpretation of who is appropriate.

An appraiser could spot certain types of real estate fraud that might require an SAR. We exempted certain folks from the main BSA training course but have a "basics" course that they must take - it is a presentation by the BSA officer.

I think the only folks we have exempted are our couriers.

We have not exempted any job function from BSA training. In a lot of cases, BSA does not apply to the job, but I believe that a little knowledge doesn't hurt anyone.

I heard a senior Fed examiner yesterday tell a story about his favorite SAR, one where a proof operator had noticed travelers checks in sequential numbers in one deposit and then saw the same thing in another deposit a few days later and called the BSA officer. The SAR that conversation generated yielded considerable interest from law enforcement.

The current regulatory suggestion is that you develop a BSA training matrix by position; e.g. the column headings might be postion and the row headings by content. They are not only accept, but distinctly prefer that you train employees on the compliance aspects that are applicable to them (the senior lender doesn't need to know how to fill out a CTR). I believe they will question any decision you make that an employee can be excluded from training.

The emphasis you hear in months to come will be on "enterpise wide" BSA compliance programs. If the "enterpise" is one bank, fine. If the enterprise is a 7 bank holding company with 2 other financial subsidiaries, the concept will still be "enterprise wide" and that's they way they will look at training too.

I don't know that basic BSA training is necessary for everyone, but training on suspicous activity should be. We now have a separate procedure for Suspicious Activity Reporting. In the past, this was part of our BSA P&P, but there was too much emphasis on cash transactions, so I took it out and created the separate procedure. Now everyone (except our property managment division) receives SAR training. The exhibit to the procedures lists all the types of crimes that are subject to SAR reporting (loan fraud, identity theft, etc.......) Employees are told to review the exhibit and make a list of the types of crimes they would be able to identify in their position at the bank. This type of awareness is essential!

Let's not forget our Directors. My position is that all bank employees attend BSA training. Director training is separate but perhaps more superficial.