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Minimum Training Allowed for Bank Employees

Question: 
When training bank employees, what is the minimum training allowed? We are getting a new core this year and it is going to monopolize a lot of time training for it. We want to stay within the legal guidelines and maintain a curriculum, but need to streamline it for core training purposes.
Answer: 

There are only a few regulations with specific training requirements. And none of those require training on any specified schedule. From a post a few years back from Andy Zavoina, here's the list:

  • BSA (12 CFR Section 21.21(c)(4) Provide training for appropriate personnel.)
  • Bank Protection Act (12 CFR Section 21.3(a)(3) Provide initial & periodic training)
  • Reg CC (12 CFR Section 229.19(f) provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee)
  • Customer Information Security (Pursuant to the Interagency Guidelines for Safeguarding Customer Information, training is required. Many banks allow for turnover and train as needed, imposing their own requirements on frequency.)
  • FCRA Red Flag (12 CFR 222.90(e)(3) Train staff, as necessary, to effectively implement the Program)

That said, most compliance examiners expect you to have a risk-based training program for compliance. So you should take your risk-based training program and document how and why you are adjusting that for the purpose of operational training needs.

[Note: The first two references are to OCC regulations. Your primary regulator has a similar requirement.]

First published on BankersOnline.com 3/4/13

First published on 03/04/2013

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