Now that the Super Bowl is over (congrats, Broncos!), the normal flow of the universe is to direct our attention to spring training. And that got me thinking…spring training…training…compliance… compliance training! (Hey, it’s how a compliance geek’s mind works – you know what I’m talking about!)
Surprisingly, there aren’t very many training requirements specifically stated in law or regulation. However, even when training isn’t specifically required by statute or regulation, it’s still critical that your credit union provide job-appropriate training for staff and board members. While staff members are responsible for carrying out many of the day-to-day requirements contained in regulations, and board members have the broad responsibility for directing and controlling the affairs of the credit union, both groups have a shared responsibility to ensure that your credit union complies with all applicable laws and regulations. In order to do so, they need to know the “what” and “why” of those laws and regulation.
So, on to training that is specifically stated in law or regulation:
Bank Secrecy Act [Section 5318(h)] — Requires financial institutions to have an anti-money laundering program that includes an ongoing employee-training program.
NCUA Rules and Regulations §748.2(b) — Requires all federally-insured credit unions to have a Bank Secrecy Act program in writing, approved by the board of directors of the institution, and noted in the minutes. The program must provide training for appropriate personnel. However, while no interval is mandated for providing that training, from a practical standpoint (i.e., what examiners or auditors are looking for) you would be foolish to conduct training less than annually.continue reading »