Answer:
Answer by Lucy Griffin:
Two regulations, BSA and Reg CC, have specific training requirements. Other regulations, such as privacy, CRA and fair lending (including ECOA) include training in the examination procedures. The bottom line is that you should cover all compliance topics about every year.
Keep a notebook of training for the examiners. Include schedules, materials use, and signed attendance lists in the notebook.
Answer:
Answer by Mary Beth Guard:
Also, don't forget the need to train under the regs carrying out the Bank Protection Act. Regulation H, for example, provides at Section 208.61(c)(1) that the bank's "security program shall: * * * (iii)Provide for initial and periodic training of officers and employees in their responsibilities under the security program and in proper employee conduct during and after a burglary, robbery, or larceny".
The Information Security Guidelines also specifically require you to "Train staff to implement your information security program."
First published on BankersOnline.com 2/11/02
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