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Regulatory Training Requirements: Every 18 Months?

An examiner (OCC) told me all employees have to be trained on each regulation every 18 months. Where can I find this requirement in the regulations?

Answer by John Burnett:

You won't. None of the regulations specifies a training frequency. Although each examiner may have an opinion as to how often training needs to take place, it would be nonproductive, for example, for a teller to take Truth in Lending training every hear and a half, and your loan operations staff hardly needs regular Truth in Savings training.

You will need to assess your own training needs, including frequency, and adjust them as there are changes in rules or if you see that your schedule (or curriculum) isn't doing the job


Answer by Andy Zavoina:

I am in agreement with John. While some regulations require training, there is little or no reference as to the exact frequency. Your own risk assessment, balanced with the duties of the employee will determine when and how often training is needed.

Here are specific requirements where people often insert "annual" in the text, but it may not in fact be there.

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.)

This may not be the opinion of my employer and should not be relied upon as legal advice.

First published on 04/14/03

First published on 04/14/2003

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