Question & Answer

Question: How often should a bank conduct compliance training? I know there are specific requirements for training on BSA but are there any specific requirements for lending regulations?

Answer: Although lending regulations do not contain specific requirements for lending, you should maintain regular training programs on these regulations. In fact, examiners are now reviewing your training programs as a part of the compliance examination. Your training schedule for each regulation or product should take several factors into account.

First, everyone new to a job should be trained for that job before they take on the responsibilities (or as soon as possible). This includes new hires, promotions, transfers, and filling in for someone or taking on extra responsibilities.

Second, using the principle that no-one's memory is perfect, you should conduct regular retraining. This can be done in the form of a review, a staff meeting, or even a game. The goal should be to refresh memories.

We recommend training or reviews for each regulation at least once annually. Training for new employees or employees new to the job may need to be more frequent. You should schedule that based on your bank's hiring and promotion practices.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 2, 1/96