ABA Bank Compliance - May/June, 2009

TRTRAINING ROOM BY MAUREEN CAROLLO, CRCM

Top 10 Answers to
Two Training Questions

WELCOME BACK TO THE TRAINING ROOM. It is kind of early in the morning for today’s workout, and it might take little longer than usual to wake up this time, since some of us may have been hibernating a little more than we should during the off-season. The last session dealt with fair lending, which is always a hot topic, especially in the winter months. Now we need to get ready for spring training, so here goes with some positive springtime thoughts:

Ah, the joys of happy thoughts … like the smell of fresh coffee, the color of springtime flowers, a bowl of chocolate anything, the first pitch on opening day, the sight of a clearance sale sign on designer suits, the e-mail about that compliance training session next week, and … wait just a minute! Who said compliance training was allowed in this list of glorious things? This is not at all like the “Top 10” plays of the day on ESPN’s Sports Center— this is more like the top 10 list on Late Night with David Letterman!

More than likely this is what any person responsible for training will brace him- or herself to hear when walking through the bank after sending that e-mail about the upcoming training session. You know the one where you send the e-mail with the date, time, location, materials, and topic and you think, “Who said all the employees have to collectively grumble, ‘Compliance training at 8:00 in the morning? I would rather stab myself in the eye with a fork.’”

Well, OK, maybe they don’t say it’s that bad, but most bank employees do dread compliance training. Why is this? Have we really had “Helga the Horrible” or “Tom the Torturer” providing these training sessions? Possibly, but more likely the trainer simply didn’t

utilize the options available to soften the blow, so to speak, of the usual training session. Of course this is not fair for the current trainer (you), but a recent informal survey of other compliance training “survivors” may shed some light on what our students dread the most and help us identify at least a few ways to prevent flashbacks from coming to your students before, after, or heaven forbid during these required sessions.

We could look at it this way: Compliance training is a necessary evil. Our examiners like to know that all bank employees in all areas of the bank are being tortured, I mean trained, on a regular basis. With all of the regulatory changes coming up in 2009 and beyond, this expectation will not diminish any time soon, but will likely increase as it has continued to in recent years, avalanche-style. All of the regulators we have ever spoken to say they are usually happy to receive copies of training session sign-in sheets, PowerPoint materials, hand-outs, and testing results, but does this documentation really indicate the sessions’ effectiveness? I think we can all agree that it doesn’t always. A training session with Meg Sczyrba, your previous trainer, covered regulator expectations in detail and offered some ideas on beefing up our muscle in this area.

Our Survey Said …

We know we need to document our training files well, but obviously the ultimate goal is to make sure that the training sticks in the first place. How do we do this? By making the training effective, obviously, but what works for one person doesn’t always appeal to the masses. What does appeal to the masses? What doesn’t?

We recently took a survey to find out what burning issues our students dread the most or want to see addressed in different ways. Our contestants include representatives from the following positions: loan officer, bank regulator, human resources director, bank president, loan administrator, teller, and compliance officer (they have to attend a bit more of this compliance training and they apparently have some very strong opinions). It was amazing how many respondents answered one question with another question; those responses remain as part of the control group of answers.