I have an employee training question please. We are in the process of hiring two part-time employees to be used as receptionist during the summer for vacations and when other receptionist is out sick. They will not have bank email, access to our core system or network. My question is, are they required to do BSA training? Thanks!

It's up to each BSA Officer to determine which staff members should have BSA training, and to what degree based on job function. Does a receptionist need to know how to complete a CTR? Probably not. Should a receptionist know what to do when a customer comes in asks them, "Hey out of curiosity, do you guys have to do anything if I bring in a lot of cash?"

Depending on the degree of interaction with customers and potential customers, you should also consider an overview of the principles of fair lending.

I'd err on the side of caution and train them in my shop. Especially since they will frequent contact with the public and customers. You'd be amazed at how chatty some people get with a receptionist and you never know, if trained properly, what the receptionist will pick up on that is suspicious. I think you'd have a hard time convincing an examiner why you felt it wasn't necessary to train that person.

Couldn't an untrained substitute receptionist start the Reg. E error resolution clock running without realizing it?

Agreed Richard, and so many other things come to mind. We train our receptionists on the same areas other staff members are required to be trained on. I see no need to exclude them if they have customer contact.

The Fair Lender training need not be the same as a loan officer or underwriter, but everyone needs to understand that all individuals need to be treated in a similar manner. I remember vividly a training film from the mid '90's where a worker came into the bank first, followed by a well dressed customer, and the well dressed customer was taken first.

It would be a good time to explain the salient points in the bank's HR manual about treating all people who come in contact with the bank - mail, phone, person, etc.

Don't forget Bank Protection Act - robbery procedures, if they are in a branch environment.

We have a retired employee that, outside of helping at bank functions, works at the reception desk maybe a handful of times each year. Examiners told us she needed to receive annual BSA training.