What's Your 2019 Training Plan?
Happy holiday season from Community Banker University! In this month’s newsletter, learn what employee training is required by regulation, see what training examiners expect, and receive ideas to grow your employees’ knowledge and skills.
With 2019 fast approaching, this is the optimal time to ensure that you have a training strategy in place to achieve your community bank’s organizational goals for the new year.
The following regulations require annual training:
- Bank Secrecy Act/Anti-Money Laundering Act – citation 12 CFR 21.21(d)(4)
ALL employees of the bank must receive annual training on BSA/AML that covers each area of BSA (CIP, suspicious activity, OFAC, etc.). Examiners are looking
for the training that employees receive be tailored to the individual job function rather than cookie cutter training. For those banks subscribed to online training plans with access to our full library of courses in 2018 we launched all new BSA
courses specific to job function so that you can meet examiners’ expectations. Available BSA courses include:
- BSA for BSA & Compliance Officers
- BSA for Frontline and Deposit Operations
- BSA for Lenders and Loan Operations
- BSA for All Personnel (directed towards administrative, IT, marketing, and marketing job functions)
- BSA for Senior Management and Directors
- BSA: Customer Due Diligence and Beneficial Ownership
- BSA: Information Sharing
- BSA OFAC Compliance
- BSA: Red Flags
- BSA: Reporting and Recordkeeping
- Regulation CC: Expedited Funds Availability Act– citation 12 CFR 229.19
Regulation CC allows banks to train only those employees affected by the requirements of this regulation. This would include frontline/retail and operations
staff. Some banks expect lenders to be able to answer deposit account questions, therefore lenders also receive Reg CC training. For those banks subscribed to online training plans with access to our full library of courses, in 2018 we launched
two new Reg CC courses that fit those whom are customer facing and those that are behind the scenes. Available Reg CC courses include:
- Regulation CC: Funds Availability Act – In Depth
- Regulation CC: Funds Availability Act – Overview
- Bank Protection Act: physical security – citation 12 CFR 21.3(a)(3)
ALL bank employees must receive annual training on their responsibilities under the bank’s security program and in proper employee conduct during and after
a robbery. For those banks subscribed to online training plans with access to our full library of courses, in 2018 we launched nine new bank security courses. Refer to the Online Training Catalog for descriptions of each in order to assign appropriately.
Available security and robbery courses include:
- Robbery Prevention Techniques for Security Officers, Executives and Managers
- Robbery Response and Aftermath Techniques for Security Officers
- Robbery Response Techniques for All Personnel
- Security: An Orientation
- Security: Laws, Rules and Regulation
- Security: Personnel
- Security: The Department
- The Annual Security Program Report
- Workplace Violence Issues for Security Officers
- Fair Credit Reporting Act Red Flags – citation 12 CRF 222.90(e)(3)
Banks are required to establish an Identity Theft Prevention Program and then train necessary staff on implementing the program. All online training plans include
the course “Red Flags Identity Theft Prevention Program” that covers training requirements. Employers will want to be sure to provide the bank’s policies and procedures for their specific program.
- Customer Information Security – pursuant to Interagency Guidelines for Establishing Information Security Standards
The guidelines require financial institutions to train staff to prepare and implement its information security program.
The institution should consider providing specialized training to ensure that personnel sufficiently protect their customers’ non-public personal information. All online training plans include the course “Gramm-Leach-Bliley Act
Primer on Privacy” that covers the training requirements.
Examiner Requested Training
The following regulations do not state that annual training is required; however, we are hearing that examiners expect formalized training for specific job roles within the bank:
- Fair Lending
Fair lending related regulations such as the Equal Credit Opportunity Act, the Fair Housing Act, the Home Mortgage Disclosure Act, and the Community Reinvestment Act do not technically require annual training, however banks
should provide fair lending training to all lending personal as well as senior management and bank directors. “Fair Lending Laws” is the course to enroll the appropriate employees in to meet examiner expectations.
- SAFE Act
The regulation states that all employees of an institution who are mortgage loan originators (MLO) be informed of the registration requirements of the SAFE Act and all other requirements of the SAFE Act. Banks should take time
each year to inform their MLOs of their requirements under the SAFE Act and ensure that they have general knowledge and understanding of all lending regulations. There are a host of online courses within the catalog to keep your lenders well informed
of lending laws. In 2019, look for a new SAFE Act course specifically for MLOs.
Other Training Opportunities
Cultivating a learning culture in your bank has countless benefits. It encourages professional growth and greater confidence and engagement amount your team. It is also a critical component in the acquisition and retention of employees. For those banks
subscribed to online training plans with access to our full library of courses make sure you and your employees are looking beyond the required compliance and security courses and dig into the other offerings. Catalogs include more than 70 courses
on communication, customer service and sales, management and leadership and personal development.
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The course “Elder Financial Abuse” was re-released on Dec. 5 with new content and appears in the new course format. Any new enrollments in this course will automatically receive the new version.
Did You Know?
If you are looking for an easy way to enroll your employees in courses that are required by regulators, refer to the courses that are included in the CBU Mandatory Course Bundles (Full Access Plans only). These bundles of courses are based on an employee’s
job function and grouped into one course. By selecting a bundle administrators only have to enroll the learner in one course, which then assigns the learner to the required individual courses automatically. Course bundle details can be found in the
catalog under Compliance – Bank Regulation starting with CBU Mandatory Courses – Audit Staff. They can also be found in the Online Training Catalog.
If you have any questions, concerns or comments regarding the great improvements we are making, please contact a Community Banker University team member at 800-422-7285 or firstname.lastname@example.org.