TAKING COMPLIANCE TRAINING FROM HO HUM TO SO FUN!! Association of Credit Union Internal Auditors September 19, 2013

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1 TAKING COMPLIANCE TRAINING FROM HO HUM TO SO FUN!! Association of Credit Union Internal Auditors September 19, 2013 Presented Date by: or Kathy subtitle Enbom, CRCM Wipfli LLP Wipfli LLP 1

2 Agenda Why train on compliance? What training is required? Who should participate in the training? What should be included? Frequency of Training Training Methods is it possible to make compliance training fun? Creative ideas for review and testing What should be in your toolbox? Wipfli LLP 2

3 Trivial Trivia How long does it take the average person to fall asleep? Wipfli LLP 3

4 Trivial Trivia 7 minutes Wipfli LLP 4

5 Why Train? Compliance is NOT the profit prevention department WIIFM your business and your employees Did you ever wish you weren t the one in the emergency row? Wipfli LLP 5

6 Why Train? Is compliance part of job descriptions and performance evaluations? Job descriptions tell staff they have to do it Training how to do it Performance evaluations - accountability Wipfli LLP 6

7 Why Train? Is compliance part of job descriptions and performance evaluations? Examples: Conduct all duties in compliance with applicable laws, regulations, and internal policies and procedures. Maintain current knowledge of applicable laws, regulations and issues related to the [loan] [deposit] [other ] operations Wipfli LLP 7

8 Why Train? Assist the compliance officer in preparing for audits and regulatory examinations. Provide timely responses to examinations and audits. Assist the compliance officer in developing and implementing plans for correcting deficiencies noted in examinations and audits. Performance evaluations just restate the job duties Wipfli LLP 8

9 Required Training What do I have to train on? It depends Different for every organization Regulations and guidelines allow flexibility Wipfli LLP 9

10 Required Training BSA o Provide training for appropriate personnel. Interagency Guidelines for Safeguarding Information otrain staff to implement the credit union s information security program. Wipfli LLP 10

11 Required Training Federal Credit Union Handbook o To assure sound personnel and operational management, the board should establish training programs for officials and employees. Wipfli LLP 11

12 Required Training Privacy o Provide training to employees whose duties are affected by the requirements of the regulation. Wipfli LLP 12

13 Required Training FCRA/FACT Act - Identity Theft Red Flags Guidelines o A covered entity must train staff, as necessary, to effectively implement the Program. Wipfli LLP 13

14 Required Training FCRA/FACT Act - Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies o Training staff that participates in activities related to the furnishing of information about consumers to consumer reporting agencies to implement the policies and procedures. Wipfli LLP 14

15 Required Training Regulation CC o A credit union must establish and maintain procedures to ensure its compliance with the regulation. It must also provide a statement of applicable portions of the procedures to employees who perform tasks subject to the requirements of the regulation. (229.19(f)) Wipfli LLP 15

16 Required Training Fair Lending oncua Consumer Compliance Self Assessment Guide Provide training to all employees involved in any aspect of residential real estate. All employees should be provided with training on the basic principles of FHA, along with other relevant fair lending laws and regulations. Wipfli LLP 16

17 Again Why Train? Regulatory exam your performance evaluation. Adequacy not determined by number of sessions, but on effectiveness. Wipfli LLP 17

18 Training Content Regulation Policies and procedures Duties of the individuals Testing Don t forget training for the Board Wipfli LLP 18

19 Frequency Dictated by regulation? Per policy New employee, new position Examiner expectation Other Create a plan Wipfli LLP 19

20 Frequency Area of Training Security/Hold up FACT Act and Red Flag Guidelines Frequency Annual Annual Last Trained Mar June Trng Month 2013 March Training Methods Computer / Online Live X June X X P&P Review Other Wipfli LLP 20

21 Training - Other Circumstances Other circumstances which prompt a need for training when the roadmap takes a detour: onew and revised regulations or heightened emphasis onew and revised policies and procedures onew and revised products and services odeficiencies noted in internal or external audits and exams (per BSA manual) oother Wipfli LLP 21

22 Trivial Trivia Who coined the phrase Honesty is the best policy? Wipfli LLP 22

23 Trivial Trivia Ben Franklin Wipfli LLP 23

24 Training Methods Computer/web based Good for tracking, testing Suggest rotating courses Instructor led/classroom who? Self study i.e. read an article, review the new or revised policy Consider multi-faceted approach for maximum effectiveness Wipfli LLP 24

25 Training Methods Make it FUN! oreal life (sort of) scenarios (BSA example available for download) ogroup participation odon t single out individuals oskits, songs, etc. that s tricky Wipfli LLP 25

26 Evidence of Training If it wasn t documented, it wasn t done Retain evidence of training and materials Track attendance or completion ospreadsheet osign-in ooutlook voting buttons oother who did not attend? Report all training to the Board Wipfli LLP 26

27 Creative Ideas for Review and Testing ogames small or large groups, indiv Jeopardy (download available) Family Feud Trivia - individual? or groups (download) Who wants to Be a Millionaire? Survivor Card games poker Consider combining games phone a friend/compliance officer, free spin Wipfli LLP 27

28 Creative Ideas for Review and Testing oworksheets opuzzles (links available for download) BSA Puzzle available for download otrivia daily/weekly contests oyour ideas???? Wipfli LLP 28

29 Jeopardy game available for download Welcome to Wipfli LLP

30 Your Host is... Wipfli LLP

31 BSA ID Theft Red Flags Fair Lending Privacy/ Safeguarding Potpourri Wipfli LLP

32 The name of the Bank Secrecy Act Officer A 100 Wipfli LLP

33 What/Who is JANE DOE Wipfli A LLP 100

34 Trivia game available Trivia game for download available for download TEAM NAME ROUND 4 UDAAP QUESTIONS ANSWERS. What does UDAAP stand for? 1.. Which products does UDAAP apply to? 2. Give an example of a practice that may be. considered unfair or deceptive. 3. Provide an example of 1 step the financial. institution can take to help avoid UDAAP issues. 4. Wipfli LLP 34

35 Trivia Score Board Team Names Round 1 Round 2 Round 3 Tyrannosaurus Rexes Round 4 Round 5 Total The Ultimate Four Troublemakers Girls and a Guy Five Alive Three's Company Wipfli LLP 35

36 WINNING AT POKER HIGH CARD ONE PAIR TWO PAIR THREE OF A KIND STRAIGHT FLUSH FULL HOUSE FOUR OF A KIND STRAIGHT FLUSH Wipfli LLP 36

37 Tools for the Training Toolbox Reusable games Timers, Spinners, Dice, Cards Flipcharts, other art supplies Giveaways CHOCOLATE!!! One more thing who MUST participate in the training? Wipfli LLP 37

38 Timer available for download 3 Minutes Wipfli LLP

39 1 Minute Wipfli LLP

40 9 Seconds Wipfli LLP

41 3 Seconds Wipfli LLP

42 2 Seconds Wipfli LLP

43 1 Second Wipfli LLP

44 TIME S UP! Wipfli LLP

45 Downloads Available (contact me and I will them to you) BSA Crossword Puzzle Compliance Jeopardy Compliance Trivia Game Timer for games, etc. Tracking Employee Training Using Outlook Wipfli LLP 45

46 Wipfli LLP 46

47 Wipfli LLP 47

48 Wipfli LLP 48

49 LET S PLAY!! Wipfli LLP 49

50 Contact Information Kathy Enbom Wipfli LLP Wipfli LLP 50

51 Wipfli LLP 51

MARIANNE E. ROCHE ATTORNEY AT LAW

CORPORATE GOVERNANCE FOR FINANCIAL INSTITUTION DIRECTORS Prepared and presented by: MARIANNE E. ROCHE ATTORNEY AT LAW SILVER, FREEDMAN & TAFF, L.L.P. DIRECT DIAL NUMBER 3299 K STREET, N.W., SUITE 100 (202)