We use an online vendor for our required annual training. When I schedule training, whether it's for only the deposit side or everyone in the bank, they are given 30 days to complete the training. There always seem to be a few employees who do not complete the training by the due date. I'm just curious how others who do online training handle this? Is this something that examiners will look at (whether the training is done by the due date) or will they simply look at whether it was done at all within the year? I don't want to come across as a hard case, but I have to keep track of who has completed the training and passed the tests, as well as schedule the next training and I don't understand why anyone couldn't complete assigned training within a 30 day time frame. Of course the excuse I always here is - "well I've just been really busy". Thoughts??

Thanks!

We also use an online vendor. In our experience, the examiners have only been concerned with the training being completed during the year.
As for those few stragglers that miss the due dates - management at our bank has placed a high priority on compliance in general. IF my reminder to complete a course isn't heeded, then the individuals manager makes sure it is done within a day or two.

Completing required training in a timely fashion should be mentioned in employee reviews, i.e. it's a plus or a minus, but it gets addressed either way.

When this happens I call their manager, everyday until they complete it.

Thank you all for your responses! I feel better knowing I'm not going overboard. Unfortunately, some of the people I am dealing with are branch managers and other compliance employees.

For those audits where we review training records, if employees miss the due date it is noted in the audit report. There could be a circumstance where missing the date is justified but generally we find there is no good reason.

The response I received to an email I sent to one of the employees and her supervisor today was "As I said earlier this week, I'll get to it as soon as I can"......

This seems to be the attitude I see the most.....no big deal, I'll do it when I get to it....

Frustrating!

Unfortunately management is the only one which can change this attitude.

The last bank that I worked at had the same problems and the President finally requested that a list of past due training be forwarded to him quarterly. He personally called the individuals on the list. I am not exactly sure what he said on this phone call, all I know is that no one was ever on the list twice and the list shrank to near 0 after that first quarter.

I'm looking for the Like button on Randy's comments. That is a good demonstration of top down support.

When training is being reviewed, or any area with problems found, one question is "who was trained and when" followed by "who wasn't trained and why?"

If you review the Consumer Compliance Rating system the FFIEC put out you will find training in several places. If the bank has people missing that training, it will have a negative impact on the compliance rating and management.

We review the list of outstanding training at our quarterly Compliance and Risk Management Committee meetings. Each department head receives the list of folks that are outstanding in their areas, including sometimes themselves too. We have the Chairman, the President to two Board members on the committee so no one likes to be seen being handed a list so that worked for us. Once in a blue moon we have one or two behind by one month but generally this worked for us.

Yes, examiners care (state examiners in particular seem to focus on this heavily.) PQ's method is the most common but I have also seen the list of past-due people sent to the board on a regular basis or to HR. It really becomes a big deal if you're looking at a bank that has other issues with their 'culture of compliance' as it's so indicative of management's overall attitude.