Training is one of the four components of a successful Compliance Program. With employees being trained on the information and tasks related to their job duties, an institution can reduce the potential of non-compliance. However, training can also come at a cost. How do you ensure your training program contributes toward an efficient and successful Compliance Program and doesn't cost your institution a fortune?
A training program should start with a plan or schedule that addresses which job position will receive certain training and when the training will be conducted. The schedule shouldn't look exactly the same for all positions as it should be designed to cover regulations related to specific job duties. For example, an employee in the operations department processing wire transfers should have different training than a loan officer. Keep in mind, that all employees should receive training on the required regulatory topics. In addition, you will want to consider not only your current employees in your training schedule, but all new hires and the Board of Directors. In determining what topics to train on, you should align your schedule with your institution's Compliance Program. Focus on the areas where you tend to have errors or are higher risk. Consider any regulatory changes that have or will impact your institution and consider internal changes such as employee turnover.
Once you have a training schedule established, you will need to determine how you will execute the schedule. There are many options of how the training could be conducted. However, a training program for an institution can be expensive, so it is important to conduct useful training while keeping cost down. So what are some considerations when keeping cost down and delivering effective material? First, you will want to make sure your method of training is sufficient for your institution. Paying for computer-based training software may not be necessary if you have fewer employees and other resources available. In-person training may be better suited for an institution that is looking to address regulatory requirements and specific internal procedures in a face to face setting. Many institutions combine in-person training with computer based training to address the basics of certain regulations and provide institution specific training in more detail. Secondly, you could consider what resources are available. There may be internal employees that can conduct training on certain topics. However, it can take time to create the material and prepare a presentation; therefore, hiring a trainer to cover various topics may be more efficient for your institution. In addition, there may be services that your institution already subscribes to, which includes training material. Lastly, consider how long the training should be. Some topics may be appropriate to cover more briefly and others may require more time. For example, if your institution has minimal errors or has an automated process for certain functions, the time spent training may be brief, compared to topics where there has been regulatory change or employee turnover.
Having a training program that fits your institution is important from a business perspective, but also to your examiners. If you look to your latest exam or audit where findings or violations were noted, you may have received the recommendation to increase training in that area. Examiners tend to link the lack of training with errors or violations. With that being said, be sure to review your prior exams and audits to ensure training has been provided to mitigate repeat findings. Continue to assess and update your training schedule to stay aligned with your Compliance Program. A review of your institution's Compliance Risk Assessment along with the training schedule can assist you in keeping your program successful. In addition, don't be afraid to make changes to your schedule and train on the important topics regularly. Be sure to adequately document your training schedule, material, and completion dates. When it comes to exams and audits, documentation is key. Being able to provide the documentation to support your training program will be important.
Overall, training is a critical component to having a successful and efficient Compliance Program. Training should not be conducted because it's required, rather it should continually be assessed and used as a tool to result in a sound Compliance Program. Keep in mind, that if you are a customer of Temenos Compliance Advisory, we offer material that can be used for training including webinars and articles. Also, consider updating your training schedule for 2019 by attending our Conference April 15-17, 2019 in Philadelphia, PA.