TAKING COMPLIANCE TRAINING FROM “HO HUM” TO “SO FUN”!! 13-Taking Compliance... · TAKING...

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TAKING COMPLIANCE TRAINING

FROM “HO HUM” TO “SO FUN”!! Association of Credit Union Internal Auditors

September 19, 2013

Date or subtitle Presented by: Kathy Enbom, CRCM

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Agenda

Why train on compliance?

What training is required?

Who should participate in the training?

What should be included?

Frequency of Training

Training Methods – is it possible to make compliance training fun?

Creative ideas for review and testing

What should be in your toolbox?

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Trivial Trivia

How long does it take the average

person to fall asleep?

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Trivial Trivia

7

minutes

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Why Train?

Compliance is

NOT the “profit

prevention”

department

WIIFM – your business and

your employees

Did you ever wish you weren’t

the one in the “emergency

row”?

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Why Train?

• Is compliance part of job descriptions

and performance evaluations? Job descriptions – tell staff they have to

do it

Training – how to do it

Performance evaluations -

accountability

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Why Train?

• Is compliance part of job descriptions and

performance evaluations? Examples:

Conduct all duties in compliance with

applicable laws, regulations, and

internal policies and procedures.

Maintain current knowledge of

applicable laws, regulations and issues

related to the [loan] [deposit] [other

________] operations

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Why Train?

Assist the compliance officer in

preparing for audits and regulatory

examinations. Provide timely

responses to examinations and

audits. Assist the compliance officer

in developing and implementing

plans for correcting deficiencies

noted in examinations and audits.

Performance evaluations – just

restate the job duties

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Required Training

• “What do I have to train on?”

•It depends

•Different for every organization

•Regulations and guidelines allow flexibility

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Required Training

• BSA

o“Provide training for appropriate personnel.”

• Interagency Guidelines for Safeguarding Information

oTrain staff to implement the credit union’s information security program.

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Required Training

• Federal Credit Union Handbook

o“To assure sound personnel and operational management, the board should establish…training programs for officials and employees.”

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Required Training

• Privacy

o“Provide training to employees

whose duties are affected by the

requirements of the regulation.”

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Required Training

• FCRA/FACT Act - Identity Theft Red Flags Guidelines

o“A covered entity must train staff, as necessary, to effectively implement the Program.”

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Required Training

• FCRA/FACT Act - Accuracy and Integrity

of Information Furnished to Consumer

Reporting Agencies

o“… Training staff that participates in

activities related to the furnishing of

information about consumers to

consumer reporting agencies to

implement the policies and

procedures.”

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Required Training

• Regulation CC

o“A credit union must establish and maintain procedures to ensure its compliance with the regulation. It must also provide a statement of applicable portions of the procedures to employees who perform tasks subject to the requirements of the regulation.” (229.19(f))

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Required Training

• Fair Lending

oNCUA Consumer Compliance Self Assessment Guide

“Provide training to all employees involved in any aspect of residential real estate…. All employees should be provided with training on the basic principles of FHA, along with other relevant fair lending laws and regulations.”

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Again…Why Train?

• Regulatory exam – your

performance evaluation.

• Adequacy not determined by

number of sessions, but on

effectiveness.

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Training Content

• Regulation

• Policies and procedures

• Duties of the individuals

• Testing

• Don’t forget training for the

Board

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Frequency

• Dictated by regulation?

• Per policy

• New employee, new position

• Examiner expectation

• Other

• Create a plan

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Frequency

Area of Training Frequency

Last

Trained

Trng

Month

2013

Training Methods

Computer

/ Online Live

P&P

Review Other

Security/Hold

up

Annual Mar-

2012

March X

FACT Act and

Red Flag

Guidelines

Annual June-

2012

June X X

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Training - Other Circumstances

• Other circumstances which prompt a need for training – when the roadmap takes a detour:

oNew and revised regulations or “heightened emphasis”

oNew and revised policies and procedures

oNew and revised products and services

oDeficiencies noted in internal or external audits and exams (per BSA manual)

oOther

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Trivial Trivia

Who coined the phrase “Honesty

is the best policy?”

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Trivial Trivia

Ben Franklin

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Training Methods

• Computer/web based

•Good for tracking, testing

•Suggest rotating courses

• Instructor led/classroom – who?

• Self study – i.e. read an article, review the new or revised policy

• Consider multi-faceted approach for maximum effectiveness

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Training Methods

• Make it FUN!

oReal life (sort of) scenarios (BSA example available for download)

oGroup participation

oDon’t single out individuals

oSkits, songs, etc. – that’s tricky

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Evidence of Training

• If it wasn’t documented, it wasn’t done

• Retain evidence of training and materials

• Track attendance or completion

oSpreadsheet

oSign-in

oOutlook – voting buttons

oOther – who did not attend?

• Report all training to the Board

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Creative Ideas for Review and Testing

oGames – small or large groups, indiv

Jeopardy (download available)

Family Feud

Trivia - individual ? or groups (download)

Who wants to Be a Millionaire?

Survivor

Card games – poker

Consider “combining” games – phone a friend/compliance officer, free spin

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Creative Ideas for Review and Testing

oWorksheets

oPuzzles (links available for download)

BSA Puzzle available for download

oTrivia daily/weekly contests

oYour ideas????

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Welcome

to

Jeopardy game available for download

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Host is ...

Your

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BSA ID Theft

Red Flags

Fair

Lending

Privacy/

Safe-

guarding

Potpourri

100 100 100 100 100

200 200 200 200 200

300 300 300 300 300

400 400 400 400 400

500 500 500 500 500

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The name of the Bank

Secrecy Act Officer

A 100

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What/Who is

JANE DOE

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Trivia game

available for

download

TEAM NAME

_____________________________________________________

ROUND 4

UDAAP

QUESTIONS ANSWERS

1. What does UDAAP stand for? 1.

2. Which products does UDAAP apply to? 2.

3. Give an example of a practice that may be

considered unfair or deceptive. 3.

4. Provide an example of 1 step the financial

institution can take to help avoid UDAAP

issues.

4.

Trivia game available

for download

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Trivia Score Board

Team Names Round 1 Round 2 Round 3 Round

4 Round 5 Total

Tyranno-

saurus Rexes 13 13 12 38

The Ultimate

Four 14 14 10 38

Trouble-

makers 14 11 13 38

3 Girls and a

Guy 12 15 13 40

Five Alive 13 14 13 40

Three's

Company 13 15 12 40

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WINNING AT POKER

HIGH CARD

ONE PAIR

TWO PAIR

THREE OF A KIND

STRAIGHT

FLUSH

FULL HOUSE

FOUR OF A KIND

STRAIGHT FLUSH

36

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Tools for the Training Toolbox

• “Reusable” games

• Timers, Spinners, Dice, Cards

• Flipcharts, other “art” supplies

• Giveaways

• CHOCOLATE!!!

• One more thing – who MUST participate in the training?

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Downloads Available (contact me and I will

email them to you)

• BSA Crossword Puzzle

• Compliance Jeopardy

• Compliance Trivia Game

• Timer – for games, etc.

• Tracking Employee Training Using Outlook

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Contact Information

Kathy Enbom

Wipfli LLP

[email protected]

815.626.1277

50

mailto:[email protected]

TAKING COMPLIANCE TRAINING FROM “HO HUM” TO “SO FUN”!! 13-Taking Compliance... · TAKING...

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