The level of instruction needs to be geared to the breadth of compliance knowledge and understanding among the target audience. You do not want to bore the knowledgeable by dwelling too long on basic information, nor do you want to go over the heads of the novices by speeding past the basics right to detailed, high-level issues. Another potential problem area is in gearing the content to the audience. Credit card personnel are not likely to be very interested in (or in need of) information about the right of rescission and mortgage servicing transfer notices. Similarly, mortgage-lending staff will not be drawn into instruction on tabular credit card application disclosures and open-end periodic statements (unless they are also involved in home equity line lending). Teaching Style A crucial issue for instructor-presented (as opposed to computerbased or similar format) training is the selection of the instructor. You want to have someone comfortable with presenting to and teaching others and, preferably, someone with experience in training. In larger institutions, the training department can help in this effort, perhaps with the compliance officer attending to handle questions that probe deeper into a rule’s requirements or into more complicated situations. If no such experienced training resources are available, the institution should consider turning to outside consultants to provide this crucial instruction to its employees. In fact, outside vendors can handle most of the preparation as well as the presentation. Your involvement is cut back to one of coordinating facilities and handout materials and in helping set the subject matter and scope of the training. The professional trainer tackles most of the other jobs, including the one of actually teaching the intricacies of the particular rule(s). When To Train All employees need to receive at least some basic compliance training as part of their initial job training. As with any training, the level of detail depends on the particular position and job grade. Periodic refresher training must also be given to all employees. Some rules require this, such as the Bank Secrecy Act and Expedited Funds Availability regulations. However, even when the norm? Or are online training programs widely utilized? Or are training sessions often presented in larger, classroom-style settings? Or is there a mixture of these and other methodologies (memoranda, manuals, etc.)? Another factor in the methodology decision is the wide availability of online training programs, many at low or no cost. Various national and state bankers associations make many online training programs available to their members at no additional cost. Beyond these offerings, a number of vendors provide online programs available to bankers covering all areas of banking, including compliance issues. A successful training program likely will encompass some variety in teaching media. Different ways of teaching work better in different situations, and some are chosen by the necessity of the moment’s needs or the pressure of immediate problems. Also, some methods work better for some subjects and in some situations than others. One element that should be included in any training process is some type of testing. You need to have some way of measuring the success of any training, and you should keep records of these results. The testing outcomes can point to issues that need further attention or to particular staff members who need more help to understand the rules that they must master. Many online training programs blur the distinction between training systems and reference/performance support systems. These systems will be easy to update, contain the tests and permit both initial self-paced training and ongoing just-in-time learning and support. Organizing Information Besides the choices in teaching media and methodology, there are alternatives to how compliance information can be organized for presentation. In some situations, instruction organized by regulation makes sense, particularly when a new regulation is released, when major changes are made in an existing one, or when compliance reviews or examinations reveal problems in a particular area. However, many times it is easier for the students to learn to apply regulatory requirements if a more transactional approach is taken or if compliance issues are woven into other job-related training. 21 In Touch
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