What areas of compliance training are required for new hires? Is there a time frame that the training must be completed?

Illinois law requires that new employees at financial institutions receive training regarding the financial exploitation of older adults within six months of their hire date and every three years after that. This requirement applies only to employees who have direct customer contact.

In addition, there are several federal regulations and guidances that require compliance training (when relevant) for bank employees, but none of these requirements apply specifically to new hires. General compliance training areas include BSA/AML, physical bank security, funds availability, identity theft, information security, and overdraft protection programs. You may review our list of resources below for links to these general employee training requirements, but please note that we cannot guarantee that this list includes all possible state and federal employee training requirements.

For resources related to our guidance, please see:

  • Financial Exploitation Training, 89 Ill. Admin. Code Section 271.120 (“New employees and officers of a financial institution who are hired after August 1, 2011 and who will have direct customer contact must satisfactorily complete financial exploitation training within 6 months after entering into new or different positions and complete refresher training every three years thereafter.”)
  • Bank Secrecy Act, 12 CFR 326.8(c)(4) (Requires banks to “[p]rovide training for appropriate personnel.”)
  • Bank Protection Act, 12 CFR 326.3(a)(3) (Requires banks to “[p]rovide initial and periodic training of officers and employees in their responsibilities under the security program and in proper employee conduct during and after a burglary, robbery, or larceny.”)
  • Regulation CC, 12 CFR 229.19(f) (Requires banks to “[p]rovide each employee who performs duties subject to the requirements of this subpart with a statement of the procedures applicable to that employee.”)
  • Regulation V, Identity Theft Red Flags, 12 CFR 222.90(e)(3) (Requires banks to “[t]rain staff, as necessary, to effectively implement the Program [the institution’s written Identity Theft Prevention Program].”)
  • Joint Guidance on Overdraft Protection Programs (Requires that financial institutions “[t]rain customer service or consumer complaint processing staff to explain their overdraft protection program’s features, costs, and terms, including how to opt out of the service.”)