We are planning our CIP training sessions and have divided opinions about who should attend. One side feels that only those individuals who are affected by CIP should be required to attend (employees in lockbox, cash vault, etc., would be exempt). The other side feels that since CIP is part of BSA, all employees should attend training. (We have at least one all-employee "live" compliance-related training session a year as part of our compliance program so the employees are used to that.)

What are others doing for their training?

When we were audited in July last year one of the things in BSA that the examiners asked was if we train all employes. We have one that is actually exempt from training, our courier, they were fine with that. If you have anyone effected by BSA, or if you ususally train BSA bank wide, I would incorporate the same guidelines with the CIP.

I would take the middle of the road similar to a CTR. Everyone should be aware of what a CTR is, why and when, but some folks need to know how to fill it out and what goes in the blanks.

Because CIP may prompt questions, those customer contact folks need an awareness level to field questions, but the folks opening new accounts and SD boxes need a more in-depth understanding.

But I do believe there are some positions that have no need to know or at best, have heard the term and know just a little bit about it.

We will be taking an approach similar to what Andy has described. A general knowledge for everyone, more details for branch personnel and loan personnel.

We are having a staff meeting next week with everyone, when we will include CIP and USA Patriot Act with our annual BSA training. Each department has been informed of their particular responsibilities, but the staff meeting will serve as a refresher.

Everyone will attend a general training session as it will be a part of BSA training.

For the initial round, we are training only those employees impacted by CIP. For the most part, this includes our execs, branches, loan departments, mortgage, training, cash mangement, Audit, Call Center, Trust, back office personnel responsible for documentation verification, and our leasing company. The only departments we are omitting from this first round are HR, Finance, Internal Services, Tech Management and marketing.
We are training all affected employees using a web-based program we develeoped in-house. They will get the training program along with the Policy, the Q&A, and a test that must be completed and returned. The Branch employees will also get "in person" training in addition to the electronic program.
Next year, we will incorporate CIP training into our regular employees training program, so everyone will be exposed.
BC

We are requiring training of ALL employees through the use of BVS. Last time we did this with Privacy/GLB it was very successful, only executive management didn't take the courses. They will be required this time as well, but if they don't take the course the many written memos and updates from us will serve as their training.

We are suggesting to our clients that everyone receive general training (about 30 minutes). Those that open accounts (loans, deposit, etc.) should receive specific training (about 2 hours).

I really think that it is wrong to give everyone specific training. If you don't break this up I think you will bore many to death. The attitude that says "I don't care. Everyone needs to hear this" is what gives compliance people a bad name.

David's suggested time frames are realistic. I just want to reiterate his suggestion that training should involve ALL employees, but be appropriate for their responsibilities.

The concept is comparable to training on how to fill out a CTR. In that example, a commercial lender does not need to know how to fill out the form and that terminally bored look on his face affects everyone else in the group. All he needs to know is that the form is required and he cannot waive it for the proverbial "good customer." He gets the short session on the CTR.

In this instance, the commercial lender actually needs the longer session and, once again, an understanding that omnipotence only goes so far - he can't waive this either. Employees not directly involved simply need awareness training.