Regulatory Training Requirements
by Mary Beth Guard, BOL Guru
Question: Could you supply specific citations from the regs that show the specifics on the
training requirements? The 4 areas listed are (1) BSA (2) Reg CC (3)
Information Security regs and (4) Bank Security.
Answer: The sections of the regulations/guidelines which require training typically do not include specifics. Instead, they merely give a general directive to do training on the subject.
Training on Bank Secrecy Act requirements is required under 208.63(c)(4). It states that your BSA compliance program must provide training for appropriate personnel..
Reg CC training is mandated by Section 229.19(f). It says “[e]ach bank shall establish procedures to ensure that the bank complies with the requirements of this subpart, and shall provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee.”
The training requirement of the Information Security Guidelines is found at III(C)(2) It states you must “[t]rain staff to implement your information security program.”
Training on bank security issues is required under Reg H, Section 208.61(c)(1)(iii). That section requires you to provide for initial and periodic training of officers and employees in their responsibilities under the security program and in proper employee conduct during and after a burglary, robbery, or larceny.
You should add to your list training of appropriate staff on any overdraft protection programs your bank offers, so that they are able to explain the programs' features, costs, and terms, and to explain other available overdraft products offered by your institution and how to qualify for them. That's one of the “best practices” listed in the Joint Guidance on Overdraft Protection Programs issued by the OCC, Fed, FDIC and NCUA in February 2005 (70 FR 9127, 2/24/2005), and reinforced by the FDIC in its FIL 81-2010 in November, 2010.
The original version appeared in the March 2002 edition of the Oklahoma Bankers Association Compliance Informer.
First published on BankersOnline.com 7/29/02; Updated 1/14/10
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