What are the state’s expectations as to the new elder financial exploitation training requirements? Would the IBA’s training DVD suffice?

The IBA’s elder financial exploitation training DVD has been approved by the Illinois Department of Financial and Professional Regulation as complying with the elderly financial exploitation training rules. As stated in the rules, the training can “be by in-person training or other media, such as a DVD.” All employees with direct customer contact should complete training by February 1, 2012, and new hires with direct customer contact should complete training within six months of hire.

You should also have policies and procedures in place to document that all employees with direct customer contact have gone through the training. The rules require that a bank officer “create and maintain a record of each employee and officer of the financial institution who has satisfactorily completed training” and maintain that list for inspection by the IDFPR.