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#640678 - 11/21/06 06:41 PM Annual Compliance Training
IronWill Offline
New Poster
Joined: Nov 2006
Posts: 11
Florida
Are you supposed to require compliance training for everyone in the bank? Even for Network Administrators or Cleaning people?
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#640682 - 11/21/06 06:46 PM Re: Annual Compliance Training IronWill
Simplee Compli Offline
Junior Member
Joined: Nov 2006
Posts: 45
USA
We require training be conducted for EVERY new hire that works for our bank including temps and internships. We do not require the cleaning crew to go through it because they are contracted out by the building that we reside in.

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#640684 - 11/21/06 06:47 PM Re: Annual Compliance Training IronWill
corkygirl Offline
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Joined: Sep 2004
Posts: 4,241
middle of the country
The only bank employees that are not required to complete some degree of compliance training at my bank are the cleaning people!! All our admins, recpts, business development officers at minimum are required to take some form of training on BSA overview, CRA overview, Fair Lending, Information Security, GLBA, OFAC. We do the majority of our training using BankersTraining online courses but I also conduct face-to-face training, reminder emails, paper training with "quizzes" to be completed and returned to me.
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#640686 - 11/21/06 06:51 PM Re: Annual Compliance Training corkygirl
MadisonCali Offline
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Joined: Jun 2006
Posts: 2,515
We have an investment dealer who works in our building about 3 or 4 days a month. He has an office there, but we share no information with him, unless a customer in front of us wants to be referred.
Do I do BSA training with him? He does get annual training from his employer, a holding company...
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#640717 - 11/21/06 07:14 PM Re: Annual Compliance Training corkygirl
IronWill Offline
New Poster
Joined: Nov 2006
Posts: 11
Florida
Thanks. My fear is that if I don't require it for the Network guys, then the dam will start to crack and I'll end up trying to customize a training regimen for each job type. I was wondering, though, is annual compliance training written into the Regs or is it required because the examiners want to see it?
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#641040 - 11/22/06 12:12 PM Re: Annual Compliance Training IronWill
DeeQ Offline
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DeeQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
I would think that a network admin would be a good candidate for compliance training. GLBA and FACTA and info breaches should be covered as well as disaster recovery.
I would not however, make them take Fair Lending courses, for example. At our bank, compliance training is based on the position held.
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#641151 - 11/22/06 03:19 PM Re: Annual Compliance Training DeeQ
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
Network Admin definately gets annual training. All staff, including top level execs get annual web based training via Digital University. We decide which modules apply to each role at the bank, and then require each staff member to complete 1-3 modules each quarter. Our corporate trainer and compliance officer review via the web the progress and scores of each staff member. Staff have 6-14 moduales a year to complete based on their roles and exposure.
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#641213 - 11/22/06 04:06 PM Re: Annual Compliance Training #Just Jay
Andy_Z Offline
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On the Net
The decision on who to train and to what degree is yours. Emphasis is on the degree of training.

The question is, is this person affected? The teller needs Reg. CC, the lender doesn't. The lender needs flood, the teller doesn't.

As a professional nit picker there are few regulations that "require" training and none that I can think of say "annual." Rather that is an industry standard. But bear in mind that in some cases that may not be enough.
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