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 not required explicitly, the financial institution supervisors expect that the expertise of all employees will be maintained by an appropriate amount of ongoing training. Such regular retraining is also in the institution’s best interest to help minimize the risk of noncompliance and can be an integral part of your risk management program. Beyond the routine refresher training, any time a new rule is issued or an existing one is changed, all affected personnel need to be updated on the new requirements and expectations and how they must implement them. Keeping Records Part of any training program should be an appropriate method of keeping records. At its most basic level, this will provide documentation of who received what compliance training and when. Records that can be kept might include sign-up sheets for in-person training, completion and testing results for online programs, sample training materials and so forth. Maintaining appropriate records allows the bank to make sure it is keeping up with compliance training needs throughout the bank and that all affected personnel are receiving (and completing) appropriate training. A side benefit of good records is that the bank can demonstrate to examiners how it is meeting their expectations in this area. The Bottom Line As we have discussed, appropriate training is crucial to success in managing the risks associated with the profusion of consumer protection laws and regulations. The elements we have reviewed can also be applied to training in other areas or aspects of employees’ jobs, not just to compliance. William J. Showalter, CRCM, CRP is a Senior Consultant with Young & Associates, Inc. (www.younginc.com), with over 35 years of experience in compliance consulting, advising and assisting financial institutions on consumer compliance and compliance management issues. He also develops and conducts compliance training programs for individual banks and their trade associations and has authored or co-authored numerous compliance publications and articles. Bill can be reached at (330) 678-0524 or wshowalter@younginc.com. vCISO for audit coordination and more…. Penetration tests Vulnerability scans Cybersecurity tailored to community banks, because it was created by community bankers! Effective training is a good preventative measure to avoid or reduce noncompliance and its associated risks. It also can contribute to better levels of customer service as staff members become familiar with what is expected of them and why particular disclosures must be given, or information must be collected. Not least among the benefits, knowledgeable employees performing their jobs right the first time can significantly reduce the operating costs of the institution, slashing expenditures for correcting errors or oversights and preventing costs associated with litigation or regulatory enforcement actions. 20 NEBRASKA INDEPENDENT BANKER
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