Have you ever found yourself sitting in a training session wondering, “what is the point of this?” Certainly, you’re not alone. Some training certainly seems more valuable than others, and the subject of the training is as important as whenyou’re training. For most of us, I’d imagine that training is something that mostly happens when you’re first hired, and something that happens again annually on certain topics. For instance, everyone must receive annual training related to the Bank Secrecy Act (BSA). However, some of the most important training will be ones that don’t happen at either of those times but happen as needed when regulatory changes arise, because training isn’t really about satisfying requirements, it’s about knowing the right things to do the job well.
Bank regulators notoriously publish new rules and issue guidance without warning, with some having immediate effect and some not having effect until a while later. In either event, these regulatory changes may fall in between annual trainings, causing the need for mid-year training. Specifically, how this training is done is up to the bank, and training should never be seen as a one-size-fits-all process. Each institution is going to have its own criteria, its own goals and even its own budget when it comes to providing training to its employees, so Bank A’s training isn’t necessarily appropriate for Bank B, and Bank B’s training doesn’t always meet the goals of Bank C.
Compliance Alliance maintains a Regulatory Compliance Calendar to help with keeping up with active comment periods and the effective dates of rules. Additionally, this calendar contains our updated schedule for huddles, back-to-basics webinars, regular monthly webinars, and any other training-type resources that are scheduled in advance. Coming up in June we have a back-to-basics webinar on Reg. E Error Resolution and Liability (register here), a monthly webinar on Annual BSA/AML Training (register here), and our monthly Compliance Huddle (register here). Further, the calendar notifies that comment period will close on June 11 for a notice and request for information and comment related to the extent to which Model Risk Management principles support BSA/AML and OFAC requirements (link).
With the General QM rule’s mandatory compliance being delayed from July 1, 2021 to October 1, 2022 (although creditors will still have the option of complying with either the original, DTI-based General QM loan definition or the revised, price-based General QM loan definition until October 1, 2022), the next regulatory effective date on our Regulatory Compliance Calendar is the Final Rule on Net Stable Funding Ratio (link) which is effective as of June 11, 2021.
We consider our Regulatory Compliance Calendar to be a “must-check” when it comes to planning upcoming trainings and generally staying ahead of the regulatory changes. The calendar works in conjunction with our daily e-mail updates which provide updates about new and improved tools which are used in providing or developing trainings for your staff. Keeping up with our calendar and subscribing to our daily e-mails provide the preparation for changes and enable you to provide relevant and accurate training when the time is right.