We're taking a new approach to new hire training, and I want to see if any of you disagree:

1. Regulations do not specify any new hire training deadlines. Our new default appears to be that no one is treated as a “new hire” per se, but instead, everyone just gets all the annual training, every year, and new hires need to “catch up” on whatever they missed in the first part of the year. Works for me! Eliminates a ginormous spreadsheet which I analyze weekly, to look for new hires who are incomplete on some or all of their training. New hire training is substantially the same as annual training anyway. There is no reason of which I’m aware to have separate compliance training programs for new hires vs. existing employees. The courses we use don’t have levels like beginner, intermediate, etc. It's just "HMDA" and "BSA" and "Fair Lending," etc. - you get the same course every year, subject to updates of regs. I'm a little concerned about how, and whether, a December new hire could possibly catch up, particularly if they start late in the month. Maybe we'd just tell them not to start training until January of the following year.

2. On the individual level, if Teller Sally Doe takes training in January 2017 and again in December 2018, her training was “annual.” (Our new default will be to launch training once a year - perhaps with staggered due dates to avoid having everyone wait till December. The downside of launching annually rather than quarterly is that some folks will or might complete all annual training in January 2017, but then might not complete it again until the following year in March or even December, thus, on the individual level, training could appear to occur considerably less often than every 12 months, yet still would occur once during each calendar year. I think other banks take the approach that training once each year between Jan. 1 and Dec. 31, every year, is “annual” training. It's perhaps overly conservative and defensive to say that training becomes less often than annual if I use a March 2017 due date for BSA then a September 2017 due date for BSA. In the past I've always had the same courses have the same due dates - but I've allowed 90 days for completion (say, Jan to March 2017). So even with my old method, someone could have taken it in Jan 2017 and then March 2018, and they would have been less often than every 12 months that way too.

OP here: I mean March 2017 and September 2018, in that sentence.

So your policies and operating procedures are identical to every other bank, convenience store, or other business that previously employed your new hires? Shouldn't you be teaching these people how YOU do things? Shouldn't that be done before they ever see one of your customers?

Agree with Richard on this. To tell a new hire just to get caught up is a bad idea. How are they going to know which ones to focus on first.

What could go wrong --

a. customer runs into a new employee at the grocery store: "Hey, congrats on your new job! By the way, I keep meaning to tell someone that I've got some weird charges on my debit card. Do you know who I should talk to?" "No, but I'll figure it out. Give me a few days."

b. Customer walks in and asks about loans. New employee: "Yea, I know we do loans--I think I heard that you can get a home loan for around 4% right now. How good is your credit? Not so good? Well, I gotta tell you, you might want to try the bank down the street, because they're really strict around here."

"Eliminates a ginormous spreadsheet which I analyze weekly, to look for new hires who are incomplete on some or all of their training."

You indicated there is no differentiation in the training, and that you do all the work, including looking for new hires. ICBA, ABA, etc - all have automated reporting. If you are using a home grown training program, the bank is not getting it's money's worth. Training is not something just to put on paper saying "they attended", it is to impart knowledge, increase sales, reduce liabilities. It does not look like the bank is trying for any of those, especially if it is as inflexible as you indicate.

A few years ago, I was pricing training and it was under $3,000, with a selection of courses, reports who took courses, scores, number of tries, listings for those who were missing courses, etc. The courses were based on the job descriptions, with more intense subject matter for those in the jobs and a more cursory review if the job only had casual responsibilities. I think the bank is spending a lot of energies with little return. Anon - the time you are playing games with a spreadsheet is valuable time you are not doing more important work.

How can you put a new teller out on the line who hasn't received BSA training? How does that individual know to report a cash transaction that was altered to avoid CTR reporting requirements?

It's actually much worse than procedural inadequacy. Please correct me if the world has become a safer place for tellers, but 20 years ago it was a crime to assist a customer who is trying to structure CTs to evade the CT reporting requirements. The bank may be complicit, but the individual employee will be the person charged with the crime and facing time at Club Fed. It's unconscionable for bank management to hire and deploy tellers and other front line people without thorough AML training.

Still is illegal. Last I checked, the bank and employee are each liable for up to $250,000 in fines and the employee for jail time.

As Rocky mentioned, all the online training vendors have reports and templates you can set up, so you shouldn't need to keep additional spreadsheets. We have templates for New Teller, Teller and Senior Teller for example. So for the New Teller, you can set the courses they need spread out starting on their hire date, plus 10 days, 15 days, 30 days, etc. So when a new teller starts, add them to the template and then you can customize it +/- any extra course so that it ends at the end of the year with all your others, and then roll them into a new one beginning of the year. Most also have email notifications in addition to reports so you can get notifications about overdue courses.

Of course, all this doesn't mean anything unless you back it up with actual one on ones with other employees for training and sessions with their supervisor about how to apply these in their position and specifics on bank policies.