IBA Compliance Connection

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We are coming up on the three year anniversary for the required refresher training on elder financial exploitation for many of our employees. Which courses are “certified” for the requisite training? Do we need to report our training records to anyone?

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Financial institution employees must complete elder financial exploitation training that complies with the Illinois Department of Financial and Professional Regulation (IDFPR)’s rules. The IDFPR’s Illinois Financial Exploitation Training rules require that the training “minimally include information on the following subjects: 1) recognizing the indicators of financial exploitation; 2) to report financial exploitation of older adults.” 89 Ill. Adm. Code 271.120. The IDFPR has compiled a list of courses that meet these requirements, available in its FAQ document on the rule. The “approved” courses include the IBA’s Regulatory University and CD ROM courses:

Bank Administration Institute Elder Financial Abuse Definition and Prevention Course

  • Community Bankers Association of Illinois BankersEdge Elder Financial Abuse Course
  • Compliance Coach — Regulatory University — Reporting Elder Financial Abuse — Illinois version
  • Illinois Bankers Association Elder Financial Exploitation Training
  • Illinois Department on Aging — Bankers and Seniors Against Financial Exploitation (BSAFE) course
  • Illinois League of Financial Institutions – Financial Elder Abuse – Recognizing and Reporting Financial Exploitation of Older Adults

After you have completed training, the rules require you to keep a record of each employee and officer who has successfully completed the training. That record must be ready for inspection by the IDFPR at any time. 89 Ill. Adm. Code 271.130(b). According to the IDFPR, they are generally asking to see this record during bank examinations. The IDFPR’s FAQ document states that it will ask institutions to report the number of persons it has trained and that examiners “will also review for compliance during the course of their normal examinations.” The IDFPR’s FAQ document also states that financial institutions should maintain “Certificates of Completion” for each person who attends a training session:

“Certificates of Completion should be kept for each person attending the training. For classroom training, a course roster signed by an instructor certifying the names of the persons attending the course should be maintained at the institution along with a copy of the agenda and course materials. For courses not pre-approved, the institution should also maintain a copy of the instructional materials which demonstrates that the course met the requirements of the rule.”