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#1536109 - 04/15/11 03:42 PM Required Annual Training
SUSANE1 Offline
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Posts: 808
with all the new rules and regs.. for purposes of annual REQUIRED training... what should be covered.
In previous years it has been Fair Lending, BSA, Reg CC, CIP, Info Security and Robbery. Our FDIC examiners instructed us to include Directors in the Fair Lending and BSA. Any other thoughts on this subject or am I missing something NEW REQUIRED training?

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#1538880 - 04/21/11 05:32 PM Re: Required Annual Training SUSANE1
SmallTownGirl Offline
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Joined: Jan 2006
Posts: 76
We have FRB in at the moment. First time we've been examined on Red Flags. We trained in 2008 when it first came out and 2009 as a refresher but not 2010. We're getting written up -- they said it's a required annual training.

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#1538906 - 04/21/11 05:50 PM Re: Required Annual Training SmallTownGirl
Ted Dreyer Offline
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Ted Dreyer
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No, it doesn't say "annual" training, it says you must "Train staff, as necessary, to effectively implement the Program".

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#1539091 - 04/21/11 08:47 PM Re: Required Annual Training Ted Dreyer
SmallTownGirl Offline
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Posts: 76
I'm waiting to see how it's phrased in the write up. I didn't remember it as a requirement either but they're the exam team...

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#1539438 - 04/22/11 03:40 PM Re: Required Annual Training SmallTownGirl
Moman Offline
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Posts: 505
WA
We have bank-wide training on ID Theft on an annual basis.

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#1539500 - 04/22/11 04:22 PM Re: Required Annual Training SmallTownGirl
A_G Offline
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Playing devil's advocate here.

Were there changes to your Red Flags program?

If so, and if I was the examiner, I would argue that staff training would be necessary because the program could not be effectively implemented without training on the changes.
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#1539515 - 04/22/11 04:30 PM Re: Required Annual Training SmallTownGirl
Patsy Cline Offline
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Patsy Cline
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On the road...
What does your policy say about training? We include it in our annual training and our new employee training.
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#1539773 - 04/22/11 06:53 PM Re: Required Annual Training Patsy Cline
Andy_Z Offline
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In many cases, annual training has become the industry standard. There are six areas that require training.

1. BSA (12 CFR §21.21(c)(4) and §208.63(c)(4) Provide training for appropriate personnel.)
2. Bank Protection Act (12 CFR §21.3(a)(3) and §208.61(c)(1)(iii) Provide initial & periodic training)
3. Reg CC (12 CFR §229.19(f)provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee)
4. Customer Information Security found at III(C)(2) (Pursuant to the Interagency Guidelines for Safeguarding Customer Information, training is required. Many banks allow for turnover and train as needed, imposing their own requirements on frequency.)
5. FCRA Red Flag (12 CFR 222.90(e)(3) Train staff, as necessary, to effectively implement the Program;)
6. Overdraft protection programs your bank offers. Employees must be 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. This is 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.

Annual training may not be sufficient or may be to frequent. If you select the latter, be prepared to justify your conclusion based on audits and personnel interviews, just as your examiners will.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#1540341 - 04/25/11 07:15 PM Re: Required Annual Training Andy_Z
COComplyGal Offline
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Joined: Jul 2009
Posts: 75
Colorado
The ABA says: Statutorily required instruction for frontline employees includes: BSA/AML, CIP, physical bank security, information security, funds availability, and identifying theft/red flag training.
We also specifically train on RFPA and Fair Lending annually.
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