If you’re responsible for compliance at your credit union, one thing you should be aware of is that certain federal regulations, along with NCUA Rules and Regulations, require training of credit union staff from time to time. And, while other statutes do not require training, it is still a prudent thing to do since the frontline staff is usually responsible for carrying out many of the compliance requirements found in the regulations.
   Here are some examples of credit union specific training:

*Bank Secrecy Act. Financial institutions are required to have an anti-money laundering program that includes an ongoing employee training program. The Bank Secrecy Act (BSA) is the current hot topic with all of the financial institution regulatory agencies. Your BSA training should be institution-wide. Every employee needs to receive general training, and training specific to their job function, on BSA compliance. This training should include management and the board.

*NCUA Rules & Regulations Part 748.2 (b) & (c). Much like the BSA, this regulation requires all federally-insured credit unions to have a Bank Secrecy Act program in writing, approved by the Board of Directors of the credit union and noted in the minutes. The program must provide training for appropriate personnel. However, no interval is mandated for providing that training.

*Regulation CC, Availability of Funds and Collection of Checks. Section 225.19 (f) states that financial institutions must do whatever is necessary to inform employees performing tasks governed by the regulation of the requirements and establish and maintain procedures designed to ensure and monitor employee compliance with the requirements.

*Regulation B, Equal Credit Opportunity Act. Section 202.15 (c) (2) of the commentary to this regulation states that “identifying and then training and/or disciplining the employees involved” is an appropriate corrective action for problems discovered as a result of a self-test for compliance with this regulation.

*NCUA Rules & Regulations Part 748, Safeguarding Member Information. Appendix A III (c) (2) requires all credit unions to train their staff to implement the information security system.

   Set up training by starting with the five most important concepts for the topic being discussed, and build on that list. Be sure to customize the training to reflect your credit union's own philosophy, procedures and terminology. Make sure to cover any regulatory changes since the last training. Develop testing or other feedback mechanisms to ensure that each employee understands the basic principals. Be certain to document the content of your training, your training measurements, and attendance.
   The League strives to provide compliance training each year. If you have special training needs, please contact education director Bernadette Hines.

[This article is adapted from the South Carolina League’s “Noteworthy” newsletter.]

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