Compliance is a fun gig, because it touches nearly every aspect of a credit union. For example, training is a topic that comes up quite a bit. Credit unions understand that they need to train their employees and officials. But how much? What topics? What format? When those questions come up, credit unions tap their compliance officers for help.
Unfortunately, we compliance peeps often serve up the usual answer. It depends. Like it or not, that's usually the best answer out there.
What topics? What training topics must you include in your training? Some are easier than others, such as BSA, which has a clear training requirement. Another clear example is the need for "Red Flags" training. But did you know that the most recent version of NCUA's model bylaws address training, indicating that a credit union's board must establish a policy to address training for newly elected and incumbent directors and volunteer officials, in areas such as ethics and fiduciary responsibility, regulatory
compliance, and accounting. All of these training requirements are sprinkled across various regulations and guidance documents. Check with your trade association, as they may have gathered a list. NAFCU has this training list (member log-in needed) available for its members. But be careful relying on lists! Our list, for example, only tracks required or suggested training outlined by NCUA and other credit union regulators, such as FinCEN. Our list does not, for example, address HR training issues, such as sexual harassment training. You're going to have to ultimately be responsible for creating your own training program.
How much training? We get this question quite a bit. "Will this training program satisfy NCUA's training requirements?" That's a great question, but there's only one entity that can ultimately answer that question. NCUA determines whether a training program is adequate. For example, designing a BSA training program for volunteers is tricky. Do they get the same training as a teller? This guidance says no.
The board of directors and senior management should be informed of changes and new developments in the BSA, its implementing regulations and directives, and the federal banking agencies' regulations. While the board of directors may not require the same degree of training as banking operations personnel, they need to understand the importance of BSA/AML regulatory requirements, the ramifications of noncompliance, and the risks posed to the bank. Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources. (Emphasis added.)
The general rule of thumb is this: your people should get enough training so they can fulfill their responsibilities. So yes, training should be tailored to the job function. Ugh. Not easy.
Training format. Is there a required format? No. But I would think a good training program would incorporate in office, online, and out-of-office training components. Each training format has its strengths and weaknesses. A good blend allows you to reach your trainees in different ways. You never know what type of training will be the right one.
I probably disappointed some of you. If you were looking for the complete "training list," I do not have it. There is no such thing as a training "silver bullet" or "magic formula" in my humble opinion. There is no model training policy that will work for every credit union. Putting together a good training program takes a lot of hard work. But that shouldn't be a surprise. That's true for most important things in life.
Anthony Demangone is director of compliance for NAFCU and regularly blogs at www.nafcucomplianceblog.org
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