Fun times!

So management has decided that they don't want us taking any training unless specifically stated in a regulation or required by law. The only regulation/law that I can see that specifically states a training requirement is BSA. However, Reg CC states that we should update staff, etc.

I am trying to put together a "required" training list, but they won't go for it unless I have specific regulation citations that show that the training is required. We are trying to push through Reg CC (for anyone that could possibly touch a deposit), Fair Lending Laws (ECOA, Reg B), ID Theft Red Flags, and Reg P. We also would like to provide some kind of training to lending staff on Reg Z, HMDA, and/or RESPA. But I can't see where training for any of these topics is specifically stated in the regulation. Also we are looking at Fair Debt Collection Practices for our Collections dept.

Can anyone point me in the right direction? I have looked in Banker Tools and found some great resources, but they still don't point out the specific citation about a training requirement...

Andy Zavoina gave a brief recap in a thread from last year. Here is the list he put together:


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.

Thanks. I will see if they will accept the reasoning. I know our regulators will have something to say but I can't prove it...

Another topic that SHOULD be covered in AT LEAST annual training is Fair Lending. It is such a hot topic this year, and I for one would be careful to include training for all employees on this delicate subject.

wow, so no training unless mandatory? What is their reasoning behind this? They don't want staff up to date to service customers? They are trying to save money? The staff is smart enough already? Well trained people are worth more? If I train you then you will seek employment elsewhere?

The bank I am at now does ZERO trainings.....We don't have employee meetings or anything. I totally disagree with this.

Polish up your resume, because the bank is headed for a train wreck

Yep!! I am already looking for something else!

Are banks required to have trainings??? They had a loan officer here at my bank that just recently quit. She was a loan officer/compliance officer with not one bit of training. How WiLd is that?!?! You can't be both!!!!!!!

Original Anon- I guess the philosophy is to ensure that our front line staff is spending all their time working with customers. The issue is that they should be knowledgable enough to help the customers. THEY ARE NOT. You should see the number of wrong, incomplete, or missing CTRs I have...and that is after we do an annual training every year! I can't imagine NOT training them on Reg CC or Fair Lending...what a mess that would be! But management thinks it is not effective. The training does not cost us anything (we pay a yearly subscription to a 200+ course system) besides time.

Original Anon, I totally agree with you.....It's unbelievable here also!!

Even though we have an on-line training system and I've created curricula on it for all employees and employees by function, there are still some areas that I annually provided face-to-face training. One particular area is Reg CC, so that they are aware of not only the regulatory aspects, but what we do specifically as far as the form completion and authorization.

That is the direction I am thinking of going. I was able to get about 5 trainings approved (BSA, Reg P, Red Flags, robbery, and OFAc). So...what I am thinking is that I will just put together training materials for the other topics and present that to branch management. Then they can cover the topics not listed above in their branch meetings. I also like to do a BSA training in person once a year, but that has been eliminated.

You situation reminds me of a sign I saw several years ago.

Which is worse?
Training your people and risking that they will leave or
Not training your people and risking that they will stay!

Good lick

I totally agree with Randy's comment. In a post Dodd-Frank world, training will be key. How can you make sure staff members are up to speed if you are only allowed to train on existing regulations that contain training requirements? There are so many new regulations coming out, you'll never be able to keep up without training staff on the new stuff. And regulators will expect to see an increase in training, rather than a cutback.

Good luck.

I work at a bank that does zero trainings as well. This is new to me. I have only been here about 4 months. I've talked to other co-workers and they say they've never had trainings. I am thinking that since I've only been here a short period of time, it's time for me to look for something else. I am in the real estate department and I feel like I'm losing what I have already learned in the past. I have to come on here every day to keep myself updated. It's a shame....