Topic: Employee Training
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What areas of compliance training are required for new hires? Is there a time frame that the training must be completed?
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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…
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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.”…
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What training is required for the Board of Directors?
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This is not an area where a black-and-white answer is available, but the federal banking regulators have issued a lot of helpful guidance on their expectations for board training and involvement. There are several bank regulations (and one guidance) that specifically require training (when relevant) for bank employees, who may include but are not limited…
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Under the Elder Financial Training rules, state-chartered institutions are required to report twice a year. When exactly should we make the reports, and how do we make the reports?
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The elder exploitation training rules require only that you maintain reports of employees and officers who have satisfactorily completed the required training and to make those reports available to the Illinois DFPR on request. 89 Ill. Adm. Code 271.130(b). We contacted the Illinois DFPR, and we were told that the department has only requested the…
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We just signed up for the IBA’s free training courses through Regulatory University. How should we assign the courses to bank employees?
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We recommend creating customized plans for each employee, assigning courses in batches of three (so as not to overwhelm employees).
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What is the deadline for employees to complete the new elder financial exploitation training requirements?
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All employees with direct customer contact have six months to complete the training (starting either on August 1, 2011 for current employees or on the date of hiring or of entering a new position). 89 Ill. Adm. Code 271.120(d), (e). (This was a change from the proposed version of the rules, which required training prior…
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What are the state’s expectations as to the new elder financial exploitation training requirements? Would the IBA’s training DVD suffice?
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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…
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Are national banks required to comply with the Illinois elder financial exploitation training requirements?
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The OCC has informed us that they do not view the Illinois law and rules on senior financial exploitation training as applying to national banks. They do not mind if national banks voluntarily comply, but they would object to any attempts at state enforcement of the law against a national bank. Their position is based…