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Recommended Initial Training

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Question: 
What are the compliance training topics that should be given to an average new employee within 90 days?
Answer: 

This really depends on the function of this average new employee.

There are four areas of required training. While the industry standard for training is annual, this is not a stated requirement. Often you need to provide initial training and follow up training based on need. Need may be defined partially on risk, audit results, examiner comments, and what is seen in the industry.

  • 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.)

Allow for these four requirements and base the rest on a risk-based allocation. More in-depth training is also imporant based on position. BSA cannot be emphasized enough. If the new employee is in operations or loans, their needs vary. Also, what are their respective dutes in those areas. Flood and RESPA may be important to one while Reg. CC and DD may be most important to another.

First published on BankersOnline.com 1/17/05

First published on 01/17/2005

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