I'm performing an audit that covers new employee training. How soon would you expect to see new employees hired to be trained, in detail, on things like ID Theft Red Flag Program/procedures and BSA/AML/OFAC/CIP policy and procedures? I'm concerned because I can see some newly hired employees don't receive this training for over 9 months. They eventually get it when the annual training comes around for all employees.

Just don't tell me that a new teller does not receive BSA training for 9 months. Most anything else is really up to the bank.

I expect to see, in addition to at least some BSA (including CTRs for tellers), training that is needed for the employees job:

Privacy early in the job for those who access customer info
Fair lending (perhaps just equal treatment in customer contact situations for nom-lending staff)


Red flags could be an early trainng for those who will be involved in seeing/using that customer info, etc.

If they need it to properly fulfill job duties, it should be early training.

We have basic training prior to reporting to the department and further training as needed depending on job function

From what I have seen over the years, most training is performed within 30 days.

We just finished the BSA portion of our FDIC exam and they are looking at required training at the latest 30 days from the date of hire. Also, they cited us for not having 100% of all employees completing the BSA courses every year, meaning ALL employees regardless of their position. They have a ZERO tolerance for BSA training completion. Who knows what will surface as they go thru the rest of our training.

Also, they cited us for not having 100% of all employees completing the BSA courses every year, meaning ALL employees regardless of their position.

Unless you have other weaknesses within your BSA program or have violated your own internal bank policy on BSA training, ask for a regulatory citation for this finding.

We did ask for a citation and they said this was their 'new requirement'. Our BSA program is in great shape as even the examiner has stated with no exceptions other than the training. They are being unreasonable.

We did ask for a citation and they said this was their 'new requirement'.

Regulators don't get to make up "new requirements" without informing the banks. I would be escalating such a finding and the information that the examiner told to the bank higher up the food chain.

This is one examiner's personal opinion without a citation unless, like I said, other weaknesses have been identified or you are in violation of your own policy. Most such things in BSA is driven by risk. If you have a well trained staff, with little turnover and an adequate BSA program, this recommendation is ridiculous.

Our timetable goes something like this: Security - 7 days. BSA, Privacy, Red Flags, FDIC Insurance, and Social Engineering - 30 days. CRA, Deposit Regs and Elder Abuse Prevention (state requirement) - 90 days.