I am in the process of revamping the entire training program for my small institution. My predecessor previously assigned CIP to all colleagues. I disagree with this approach.

The citation indicates:
Provide training for appropriate personnel

I would consider "appropriate personnel" those involved in the CIP process, that is, account openers and their operational support (as well as compliance). As I am building my curriculum in ABA Frontline Compliance I noticed they have CIP for all colleagues. What are your thoughts?

Please note I am considering BSA/AML as a separate module from CIP.

I do give some rudimentary 'training' in CIP for all employees.

While the new accounts folks and loan processors get more details as to the 'hows' (including how to verify, recrod retention, etc.), my feeling is that everyone in the bank should at least be aware of the USA Patriot Act, why it exists, and the fact that we do collect (and verify) the four basic elements). I also tack OFAC on as well. Personally, everyone in the bank should have some basic knowledge of BSA/AML/CIP/OFAC, and then additional training based on your job responsibilities.

Perfect, I would say we're in the same boat Doug. I provide a BSA/USA PATRIOT Act training to all colleagues which touches on the elements of CIP. The CIP specific module I limit to those responsible for CIP activities.

Thanks for your response.

All of our employees receive training at least annually because it falls under our BSA/AML program.