Skip to content
BOL Conferences
Thread Options
#1137325 - 02/27/09 04:01 PM BSA Training Documentation
hawksfan Offline
100 Club
Joined: Mar 2004
Posts: 114
Iowa/Illinois
I need your opinion...will you share?

At one of our bank charters, the BSA Officer emailed the BSA materials along with a powerpoint presentation to all employees in 2008. She did not require them to respond that they had read and understood the materials. Do you think she should be requiring the employees to respond that they received and understood the materials or do you think that the email itself is sufficient to document that they were trained. I'm an auditor...I would like to see documentation that the materials were received and understood; however, maybe I'm being too picky. Your thougths would be appreciated. Thanks!

Return to Top
BSA/AML/CIP/OFAC Forum
#1137332 - 02/27/09 04:07 PM Re: BSA Training Documentation hawksfan
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Acknowlegement of the training should be documented. Sign-in sheet, email, certificates from completion (if online), etc. Otherwise people can say they didn't get training and you have no documentation to prove otherwise. Plus, the examiners will most likely look for something like that as well. But that's just my opinion.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1137476 - 02/27/09 05:26 PM Re: BSA Training Documentation J2C
Jerseygirl Offline
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
As BSA officer at a bank with over 700 employees it became very time consuming to track that everyone completed the supplemental training we sent out. (We also have on on-line training product that everyone takes and is electronically tracked.)
It was frustrating trying to get all acknowledgement sheets that the training was completed. Last year we changed our procedures. It is now the department/branch managers responsibility to see the training is completed, understood and documented. Your BSA officer may want to consider this. And then your audit procedures could be updated that when you review the department or branch you ask for that documentation. To me it seems to put the accountability on the direct supervisors.

Return to Top
#1137815 - 02/27/09 09:09 PM Re: BSA Training Documentation Jerseygirl
OkieDokie Offline
Member
Joined: Jan 2007
Posts: 51
Oklahoma
I agree with jennyfromthebloc, without documentation that training was received, I believe an examiner would be apt to have more interest in testing your employees' knowledge of BSA.

Return to Top
#1137822 - 02/27/09 09:17 PM Re: BSA Training Documentation hawksfan
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
...do you think that the email itself is sufficient to document that they were trained.


If your bank's only BSA/AML training consisted of sending an e-mail your examiners should cite you for a "pillar" violation when they walk through the door.

Beyond that, my nephew was having trouble in school and his teacher suggested that he get his eyes examined. The ophthalmologist said he was pretty much blind as a bat, suffering from the same impairment that I have.

His Mom was very embarrassed and as soon as they got outside confronted him: "Why didn't you tell me you couldn't see!" With the wisdom of an 11 year old he responded, "I thought I could!"

Asking people to sign a paper saying they understood their training is more than a tad ridiculous. How would they know if they misunderstood it completely?

If you do not test your employees your examiners are simply obliged to do it themselves. Your methods will be kinder. Training without testing is like deer hunting in the dark - you will not know whether you hit it or not.

Last edited by Ken_Pegasus; 03/02/09 01:28 PM.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z