We will train all our associates on Check 21. However, is there a regulatory requirement in the final rule that states that the training must be done by October 28th?? We are going to train them the first week of November.
Thanks.

I don't know if you are a bank, but Reg CC itself has an annual mandatory training requirement. As far as subpart D of Reg CC (Check 21) is concerned, I don't remember seeing any training stipulations, but I do have to ask why you are waiting so long to train? Your customers are going to start seeing news reports, magazine and newspaper articles and other (possibly) erroneous information before October 28th. It surprises me that you would want to place your employees in the position of not being able to respond to customer inquiries in an intelligent and informed manner.
BC

We are already seeing articles in publications and other banks are sending out Check 21 awareness brochures. I would want employees to know before the October 28th date on this one. We developed a training piece just for all employees on our intranet so all employees have a good understanding of Check 21. You may want to rethink you training plans.

I'm not sure Reg CC specifies the need for annual training? Although it certainly is a good practice.

We're finding that the customer ed brochures are generating questions, too, so I'm glad we got some Check 21 training basics in during the last two months. We'll be doing some review this month & next.