Skip to content
BOL Conferences
Thread Options
#384149 - 07/11/05 07:03 PM CRA Training
SamIAM Offline
100 Club
Joined: Nov 2004
Posts: 212
I've seen several posts for CRA Training; however, I haven't found anything that addresses my question:

Is CRA training required for all bank personnel? I didn't see anything in the reg that requires CRA training. Can someone tell me where I can find the reference? Thanks.

Return to Top
CRA
#384150 - 07/11/05 08:10 PM Re: CRA Training
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
May get some disagreement over this question, but "all staff" training and get this, a CRA policy, is not required by regulation. This falls into the area of a "best practices" type of deal. You may bet an examiner, especially the OCC, to list off CRA as a needed policy, which by definition, would include training, but you won't see it in the regs (at least not the last time I looked).
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


Return to Top
#384151 - 07/12/05 06:44 PM Re: CRA Training
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
There isn't a specific reference to training requirements that I can think of off the top of my head. Instead there are comments like "staff need to know" and "management must be informed" and "the bank must comply" which follow many of the regulatory statements. I'm not sure how your staff are going to "know" for instance, where the file is if you don't train them at some point? Also they're supposed to know if there is a branch file, and higher level management needs to know about Sunshine, etc., which means, training.

All customer contact staff need to know where the files are and how to notify the CRA office if someone wants to see the public file. All management covered under Sunshine need to know what their responsabilities are in regards to reporting so that you don't fall out of compliance in that regard, but does Proof need to know about Sunshine? No of course not. Most of us don't train our "non-contact" folks on CRA. I think generally training for most branch staff takes place annually because you don't want them to forget what they need to be aware of, and then many train boards every two years or so on pertinent information.

Training is not part of the exam though. I've never been asked for the information, but if the examiner wanders into the branch and can't get to the file, you'll find it will come up. Same if a community group can't get the information because they hit an untrained teller. At that point, you'll be out of compliance and subject to a complaint
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

Return to Top
#384152 - 07/12/05 09:51 PM Re: CRA Training
Sinatra Fan Offline
Power Poster
Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
Quote:

Training is not part of the exam though. I've never been asked for the information, but if the examiner wanders into the branch and can't get to the file, you'll find it will come up. Same if a community group can't get the information because they hit an untrained teller. At that point, you'll be out of compliance and subject to a complaint




And, of course, the examiner or community group representative could talk to a person who has been trained in CRA, and get the same non-helpful answer. Training--or at least, informing--needs to be done on a regular basis. But given the ever increasing plethora of regulations, I am very sympathetic toward an individual who has had some training on a subject that he or she will almost never encounter in their normal activities, but that he or she is expected to know should the chance encounter occur ten months or so later.

Train, document, and hope for the best.
_________________________
Management is doing things right; leadership is doing the right things. Peter Drucker

Return to Top
#384153 - 07/13/05 01:25 PM Re: CRA Training
SamIAM Offline
100 Club
Joined: Nov 2004
Posts: 212
I appreciate your comments. We do have training for management and public contact personnel. I also inform all staff where the public file is as well as the name of the CRA Officer. But I can't see everyone having to take an hour-long training that they will probably never use (those with no public contact). Thanks again!

Return to Top
#384154 - 07/13/05 09:15 PM Re: CRA Training
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Max I have a 15 min video that I loan out to departments for staff meetings. It's an ABA video. Short and sweet You might look into something like that. Even great trainers need a 15 min break in their presentation I use it when I do the branch trainings in person, then add on the local information that they will find valuable (products to sell, etc.)
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

Return to Top
#384155 - 07/15/05 07:57 PM Re: CRA Training
SamIAM Offline
100 Club
Joined: Nov 2004
Posts: 212
Thanks Dawn. I'll check with ABA.

Return to Top