We have a dual employee. He is the Investment Officer for the Investment firm in our bank and also a bank officer. I am conducting some compliance training that will touch on a general overview of a lot of the regulations such as Reg CC, required notices, BSA, EFT, etc. One of our Sr. Vice President's has asked if he could be exempt from this training. Even though he is a Bank Officer, "his duties don’t include any deposit or loan transactions". I personally think if he is representing the bank as an officer that he should attend. What do others of you do in this situation? Is it required for this type of personnel?

Given the limited amount of time personnel have to train, he has a point. If he is not selling or administering those products, he may not need some of the training you mentioned.

However, I would be careful where I drew the line. He certainly needs training on issues like BSA/AML/CIP, Privacy, Protection of Customer Information, etc.

He needs to attend - he needs to understand the regs as is the case with any officer of the bank. His customers are also your customers, so a lot of issues could come up for which knowledge of the regs would be helpful for him to have, simply from a customer service point of view.

We also have dual employees, and I recently got into the same kind of discussion. In my opinion there are certain things that this individual will need - BSA/AML, Privacy, Equal Treatment are some off the top of my head. Plus he or she needs to understand how his/her dual role fits in, so that customers are not confused, mislead, or otherwise don't understand the type of product or service that he is selling. This is an issue that I feel your examiners will ask about. What I did was a compromise on the training - I put the topics that I felt were important to everyone in the beginning of the training and allowed the dual employees to attend for those topics. Guess what, most of them decided to stay for the whole show anyway! And the feedback I got was good; they learned something. I feel the compromise worked, since they felt that I listened.

Depending on the traing we approach it from the top-down. Exec officers are expected to complete a form of training along with everyone else for BSA,AML, fair lending, and privacy. For them it might be in the form of an executive summary they can read the highlights and self certify that they read it. The signoff form goes to Training. At least we can show our regulator who took what and whether it was summary form or CBT or full training. Officers need to play along with the rest of us.