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#2250976 - 03/22/21 06:37 PM Training - passing score? Limit of attempts?
J_G Offline
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What do you all have your settings set to if you use a training vendor's website such as ABA or BAI? For example, what is your minimum passing score for training courses? And what is the limit of number of attempts an employee can take on courses (e.g., unlimited, XX attempts every XX number of days, XX attempts annually starting on MM/DD, etc)?

Also, do you have this covered in your BSA policy?

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#2250982 - 03/22/21 07:38 PM Re: Training - passing score? Limit of attempts? J_G
ACBbank Offline
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New York City
We use 70% as a passing score and allow for three attempts. This covered in a our BSA Policy, along with the remedial action and consequences for failing three times.
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#2251018 - 03/23/21 03:22 PM Re: Training - passing score? Limit of attempts? J_G
J_G Offline
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What is your remedial action and consequences for failing 3 times?

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#2251034 - 03/23/21 04:45 PM Re: Training - passing score? Limit of attempts? J_G
ACBbank Offline
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ACBbank
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New York City
We require that the employee the attend an in person training with the BSA Officer and any potential bonuses or raises are delayed for six (6) months (Possibly discontinued if they are unable to pass the remedial training). I'm not saying this is for everyone but we were pushed down this path.
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#2251037 - 03/23/21 05:22 PM Re: Training - passing score? Limit of attempts? J_G
HappyGilmore Offline
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Pulling people out of the ditc...
we have 80% as passing score, no limit to the number of attempts. honestly, the training of this nature is so watered down that anyone with half a brain and breathing can take the test without reading a lick of the training and probably pass. those that don't, the training tells you what ones you missed so you can go retake and likely pass them. we use canned FIS courses as well as some in-house developed.
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#2251055 - 03/23/21 07:04 PM Re: Training - passing score? Limit of attempts? J_G
80's Lady Offline
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We have 80% as a passing score as well, with five attempts. We set a limit to avoid someone just "testing" out and going straight to the test without reading the material. Anything over the five requires a reset by our training manager. I agree with Happy that some of the courses are easy, but not all - and of course the longer you are in banking hopefully you have a good knowledge of the material. We also assign based on job duties, which means some staff don't just get one BSA course.

We cover generally in our BSA Policy and more specifically in our training plan. All staff is required to read and acknowledge the BSA Policy annually and this is also done through the online training. We supplement online training with live training on BSA and other topics throughout the year.
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#2251058 - 03/23/21 07:38 PM Re: Training - passing score? Limit of attempts? J_G
BrianC Offline
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Illinois
Quote
We supplement online training with live training on BSA and other topics throughout the year.

This is critical. Many of my clients use online training to "check the box" to say that staff had training. However, BSA training is one of the five pillars and this approach may not be adequate. No where in the regulation does is say that training must be annual. It says "Periodic training for appropriate personnel should incorporate current developments and changes to BSA regulatory requirements; supervisory guidance; internal policies, procedures, and processes; and the bank’s products, services, customers, and geographic locations."

Is training effective? I audited a bank that used the same online course every year. The completion records showed me that some employees spent five minutes in the course. Just long enough to click through all the pages and take the same test that they had taken every year. I concluded the training was not effective based on the volume of errors I found in CIP, CDD and suspicious activity monitoring. Online courses are nice to demonstrate general BSA knowledge, but they are no substitute for additional training on bank specific policy and procedures.

Instead of worrying about "passing scores" and "retries" and "tailoring the test so that people pass" make sure that your training is geared to ensure that people know what their BSA responsibilities are for their job function and that their performance demonstrates that they know what to do.
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