Answer:
The training requirements for Regulation CC are found in Section 229.19(f). Your bank is obliged to "provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee."
Most banks don't have directors who also perform teller duties (although it would be good for a director to observe a teller at work, it would probably not be a good idea to entrust the keys to the teller drawer or terminal to the director), so there's no need to train directors on Regulation CC policies and procedures. By the way, there's nothing at all in the regulation to suggest that Regulation CC training needs to be annual. You can train new hires as needed and then provide refresher training sessions for those who demonstrate a need.
First published on BankersOnline.com 1/03/11
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