Minimum Training Allowed for Bank Employees

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Question:

When training bank employees, what is the minimum training allowed? We are getting a new core this year and it is going to monopolize a lot of time training for it. We want to stay within the legal guidelines and maintain a curriculum, but need to streamline it for core training purposes.

Answer:

There are only a few regulations with specific training requirements. And none of those require training on any specified schedule. From a post a few years back from Andy Zavoina, here's the list:

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.)
FCRA Red Flag (12 CFR 222.90(e)(3) Train staff, as necessary, to effectively implement the Program)

That said, most compliance examiners expect you to have a risk-based training program for compliance. So you should take your risk-based training program and document how and why you are adjusting that for the purpose of operational training needs.

[Note: The first two references are to OCC regulations. Your primary regulator has a similar requirement.]

First published on BankersOnline.com 3/4/13