At the recent IBA Compliance Conference, Scott Clarke IDFPR reminded attendees that banks needed to report their training efforts regarding Elder Abuse/Financial Exploitation on a bi-annual basis.

Does anyone know how this is suppose to be done? I am sending an email to Scott regarding but thought I'd check with other Illinois compliance folks as well.

Any help would be appreciate. I'll keep ya'll posted if I get a response from Scott.

Whenever I host training (whether with a whole group or one-on-one with new employees), I keep attendance on a log that employees sign and date. I also keep a copy of the training materials.

All banks, or just state banks?

My bank's compliance officer sat with each department and conducted a training session going over the Illinois Elder Abuse brochure, phone numbers for reporting, and our bank's policy on how to centralize all suspicions for investigation and reporting. Then we all signed off on a single log sheet and she put it all in a folder and said she'd be training us all again twice a year. Hope that helps. We are an Illinois chartered bank.

We're doing the training, I'm just wondering about reporting it to IDFPR. I'm surprised Scott hasn't gotten back to ComplywithMe yet, because he's usually very prompt. Must be on vacation.

I don't remember there being a requirement that we report in the training to the IDFPR on a regular basis... I thought we just kept the records for them to review when in for exams. But maybe I've missed something.

There is not a requirement to report to the IDFPR. I was at that conference, I thought that he said that they "reserve the right to ask for records" or something like that. Having said that, we are a National Bank and the IDFPR cannot examine us.

"As a matter of federal law, however, the
rule will not be enforceable against national banks or federally-chartered thrifts, which are not subject to visitation by State banking authorities and which are not
obligated to submit to reporting requirements imposed by State law or regulation."

http://www.cbai.com/downloads/Financial%20exploitation%20Q%20&%20A.pdf

Good. I thought I missed something.

BTW QCL, I love your avi!

Hopefully I'm not to late in giving ya'll an update - per Scott Clarke we DO need to report training. From Scott's email to me regarding - "The “Non-Financial Institutions Data Form” is mailed to you with the quarterly billing invoice sent to you from our office each quarter. It is on this form that you enter the information about the total number of persons trained by your institution."
My bank has recieved the form and reported our numbers per the question.

Non-financial institutions?

ComplyWithMe,
Are you a state bank?

We just received this form as well. It says, "Please indicate the number of individuals trained through June 30, 2012 in an approved Elder Financial Exploitation training class in accordance with the Elder Abuse and Neglect Act: _______."

Are you a with a financial institution CrookedVulture? The form is called Non-Financial Institutions Data Form, and I'm just confused about why it would be sent out to banks.

I am. The form we received is titled, "Commercial Bank Non-Financial Data Survey Form".

Hm. I don't think we've ever gotten one of those.

It's the quarterly assessment form. I had to give the training informaiton to our person who completes this form. Scott Clarke did say you have to report it and this, apparently, is how it's done.

Well color me surprised, after some digging I just found out that the President has been completing this form for us each quarter! Man, I love my boss.