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#2108161 - 11/21/16 08:29 PM Bank Protection Act
Renea Rush Offline
Member
Joined: Dec 2011
Posts: 74
Does this regulation require annual training for staff? I have looked over the OCC examination procedures and do not see anything about it. Management has seen training advertised that states that it is required. While I would agree that it needs to be done frequently, I just need to know if it is required by regulation.

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Security - PUBLIC
#2108230 - 11/22/16 01:22 PM Re: Bank Protection Act Renea Rush
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,406
Part 21 - Minimum Security Devices and Procedures

21.3 - Security Program

(3) Provide for initial and periodic training of employees in their responsibilities under the security program and in proper employee conduct during and after a robbery.

Hope this helps.

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#2109781 - 12/06/16 02:46 PM Re: Bank Protection Act Renea Rush
thomasj Offline
Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
The wording states periodic; however, if you do training less than annually your institution may face not only criticism from regulators but liability if something goes wrong during a security related event. With security training, I always looked at it more from a perspective of wanting my employees to have the knowledge to help keep them safe rather than as a regulatory requirement. With larger institutions it becomes difficult to do with any degree of personal interaction which is challenging.
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#2112932 - 01/03/17 11:25 PM Re: Bank Protection Act Renea Rush
Barry Thompson Offline
100 Club
Barry Thompson
Joined: Jan 2001
Posts: 121
Oswego, New York, United State...
Let me help you out here the minimum training using Regulation H would be annually. Why?

The security officer for each member bank shall report at least annually to the bank’s board of directors 208.61(d)

If the security officer is reporting annually that everything is achieved in the security program we go to this section:

Provide for initial and periodic training of Officers and employees in their responsibilities under the Security Program 208.61(c)(1)(iii)

Thus for the security officer to report that the bank is in compliance the entire bank would have had to be trained in security at least annually. Please note no exceptions exist for folks in the operations centers or any other department not being trained. The regulation exempts no one!

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