Topic: Employee Training
-
Our learning management system provides two courses on human trafficking. Are there any laws or regulations requiring banks to provide their employees with training on identifying and reporting human trafficking?
—
by
No, we are not aware of any law or regulation that requires banks to provide their employees with training on identifying and reporting human trafficking. Although the Bank Secrecy Act (BSA) regulations require banks to establish a BSA compliance program that provides training for appropriate personnel, a course on human trafficking is not specifically required.…
-
Are there specific requirements about the content or length of refresher training for Elder Financial Abuse Prevention? I know that initial training must be at least thirty minutes long. We use Bank Administration Institute (BAI) for our training, and they provide courses that are five, ten, and fifteen minutes long. Does that satisfy the requirements for refresher training?
—
by
Both the initial and refresher elder financial exploitation training programs should be at least thirty minutes long. The Illinois Administrative Code establishes the length and content requirements for elder financial exploitation training. It does not distinguish between the initial and refresher training, which should be at least thirty minutes in duration (among other requirements). Accordingly,…
-
Our bank recently completed a safety and soundness examination, and the examiner asked us to expand our training for employees designated to do real estate evaluations. These evaluations are done when a transaction does not require the services of a state certified or licensed appraiser. Do you have any training webinars available that relate to educating employees on the completion of these kinds of evaluations?
—
by
The IBA is offering an upcoming webinar titled “Dealing with Appraisals: Regulations and Requirements” that will cover significant developments in the rules and regulations covering real estate appraisals and evaluations, as well as in-depth details of the appraisal and valuation process. The webinar will take place on Thursday, March 11 from 1:30–3:30 p.m. Central Time.…
-
Does the IBA offer any sexual harassment prevention trainings that meet the requirements set forth in the Illinois Human Rights Act? We are aware the Illinois Department of Human Rights offers a model training program, but we would like to know what else is available.
—
by
Yes, the IBA is offering three streaming sexual harassment prevention training programs that meet the requirements set forth in the Illinois Human Rights Act — one for employees only, one for supervisors only, and one for both employees and supervisors. There also is an option to purchase a live virtual training customized to your workplace…
-
What training is required for a bank’s Board of Directors?
—
by
This is not an area where a black-and-white answer is available, but the federal banking regulators have issued some helpful guidance on their expectations for board training and involvement. Although the resources below are not necessarily from your primary regulator, they are good sources for best practices and advice. The OCC’s Guidelines Establishing Heightened Standards…
-
Our mortgage loan originators (MLOs) are registered with the Nationwide Mortgage Licensing System (NMLS). Must they also register with the State of Illinois? We are aware that MLOs licensed in Illinois must complete eight hours of continuing education training before the end of the year to renew their licenses. Are our MLOs required to complete this training?
—
by
No, MLOs that are registered with the NMLS and employed by financial institutions are not required to register or obtain state-issued licenses in Illinois. Consequently, the NMLS-registered MLOs at your bank are not required to complete the continuing education requirements for Illinois-licensed MLOs. Although the Illinois Residential Mortgage License Act of 1987 generally requires licensed…
-
We collect our own debts for residential home loans, and we are a large servicer for purposes of the CFPB’s mortgage servicing rules. Can you recommend any training resources on Regulation X and Regulation Z as they apply to loss mitigation? We would like to develop our staff’s ability to make critical assessments of loss mitigation situations. Any resources for developing related soft skills, such asking probing questions, also would be useful.
—
by
We can recommend a Total Training Solutions (TTS) webinar focusing on Regulations X and Z as they apply to the 2017 revised mortgage servicing rules and a webinar on mortgage servicing compliance that covers loss mitigation options, applications, and processes. Also, the American Bankers Association (ABA) provides a webinar on mortgage servicing and loss mitigation.…
-
Our customer-facing staff is trained on elder financial abuse every two years. Should this training incorporate information about the federal immunity for individuals who have received training when making a good faith disclosure of suspected exploitation of a senior citizen?
—
by
Your bank is not required to incorporate information about federal immunity under the Senior Safe Act, but it may be advantageous to do so if your training fully complies with the federal law’s requirements. The Senior Safe Act confers somewhat limited protections for banks and other financial companies from being sued for reporting suspected elder…
-
The recent federal regulatory reform legislation (S. 2155) included a new Senior Safe Act. Is this different than the Illinois elder financial exploitation training requirements? Are there any additional requirements? What does this mean for our bank?
—
by
We do not believe that the Senior Safe Act will bring significant changes for your bank. Because it does not preempt or limit Illinois law, we believe that its protections will be additive to the existing liability protections under Illinois law. The Senior Safe Act confers somewhat limited protections for banks and other financial companies…
-
We are preparing for staff refresher training on elder financial exploitation early next year. Can you confirm that Illinois still does not make bank employees mandatory reporters of suspected elder abuse?
—
by
Yes, we can confirm that banks and their employees are not mandatory reporters of suspected elder abuse in Illinois — such reporting is purely voluntary. For resources related to our guidance, please see: Adult Protective Services Act, 320 ILCS 20/2(f-5) (The definition of “mandated reporter” does not include financial institutions or their employees.) Illinois Banking Act, 205 ILCS…