Steering your Staff and Sharing the Knowledge-Creating a Substantial Compliance Training Program
Navigating the intricate landscape of compliance is a shared responsibility that extends far beyond the role of a Compliance Officer. Compliance training plays a role in enhancing a financial institution; therefore, it is critical that every employee at the institution participates in receiving relevant training.Adequate and relevant training can give employees the knowledge to better understand their responsibilities. Training can also provide employees with confidence in accomplishing their day-to-day tasks. In this article, I will address considerations for optimizing compliance training within your institution.
First, I recommend the financial institution’s Compliance Officer meet with the institution’s Human Resources department or the applicable employee responsible for overseeing training requirements within your financial institution. From there, I recommend collaborating to establish a schedule that aligns specific training content with relevant job roles. Keep in mind that when creating the training schedule, there are certain topics that are required for all employees, such as BSA/AML, and there are more specialized topics, such as HMDA, which apply to more specific job roles. Even in the case of training required for all employees, consider customizing the content to apply to particular departments or job roles. A tailored approach ensures compliance training becomes not just a requirement but a targeted and impactful tool for every employee in your financial institution.
When creating a training schedule for employees, be sure to consider all departments and affiliates when assigning required training. For example, an insurance company or investment firm linked to your institution as an affiliate would require training on various topics. In addition, don’t overlook the training needs of the Board of Directors. While they also require training, it is essential to ensure the content of their training material is different from that of regular employees. Acknowledging each department’s distinct roles and responsibilities provides a comprehensive and targeted compliance training approach that is effective.
Don’t hesitate to tailor the content of the material to the employee’s specific job duties and responsibilities. Consider the distinct needs of various roles; for instance, the training material for Suspicious Activity Reporting may differ significantly for a lender compared to an employee in deposit operations. I recommend having the Compliance Officer review the content to ensure that the material aligns appropriately with your institution’s established practices and procedures. Having the Compliance Officer review the training material not only ensures that the material aligns with the financial institution’s policies and procedures but is also highly relevant to the individual’s job duties and responsibilities, enhancing the effectiveness of the compliance training program.
Another consideration of a compliance training program is determining the method by which the training will be provided. Online training, known for its convenience and cost-effectiveness, can be preferred. However, reviewing content and assessments is imperative when opting for online training. I recommend verifying whether the test contains the right balance between being challenging without being overly complicated. Establishing a reasonable passing grade must also be considered. Setting a low passing percentage may open the institution up for examiner scrutiny. Passing the test should be attainable and beneficial. As an alternative to online training courses, consider the value of in-person training. While online training offers convenience, there are situations where in-person sessions are appropriate. For instance, when a recent regulatory change affects a specific department or there are repeat findings. In those instances, in-person training can become more effective. In those instances, structure the training to address the specific repeat findings and action to correct the issue. Overall, I recommend keeping the content current and ensuring the training method is adequate for your financial institution.
Training is essential for financial institution employees, providing the knowledge and skills to fulfill responsibilities and confidently adhere to federal regulatory compliance requirements. To access a variety of training resources, be sure to review the webinars and weekly articles available on our website. For specific federal compliance regulatory questions, contact one of our Advisors by submitting a consultation request.