Is Info Security Training an Annual Affair?

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Question:

Is Customer Information Security Policy mandatory annual training for all bank employees? We trained all employees in December 2003, when the policy was new and have trained all new employees since.

Answer:

The only mandatory training I know of are the following:
- BSA (12 CFR Section 21.21(c)(4) Provide training for appropriate personnel.)
- Bank Protection Act (12 CFR Section 21.3(a)(3) Provide initial & periodic training)
- Reg CC (12 CFR Section 229.19(f)provide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee)
- Customer Information Security (Pursuant to the Interagency Guidelines for Safeguarding Customer Information, training is required. Many banks allow for turnover and train as needed, imposing their own requirements on frequency.)

First published on BankersOnline.com 11/1/04