I would like to hear from anyone who has been asked by their examiner for Senior Mgmt training requirements and records. Currently, we are a mid-sized bank (below $1B). We require all employees/staff to go through the five required annual Complaince training and other refreshers each year, but we don't track Senior Mgmt (four executives). We leave it up to them to get their annual training. What are our risks?

Your risk is that your program will be criticized. Senior management should be tracked and required to complete the courses determined to be appropriate for them.

GK, the compliance management program can be negatively affected. Compliance is a top-down approach - if management isn't buying into it, no-one will, and the examiners know it.

Besides the course curricula, they will critique who has taken the courses, starting first with management. Like KB mentioned, the courses need to be appropriate for the job and employee

Quite frequently examiners will first ask for a list of senior management and directors who have NOT taken the required training.

We do our training with everyone personally. The BOD, CEO, CLO and EVP get theirs together at a board meeting.

Thanks for the info!