Compliance is a fun gig, because it touches nearly every aspectof a credit union. For example, training is a topic that comes upquite a bit. Credit unions understand that they need to train theiremployees and officials. But how much? What topics? What format?When those questions come up, credit unions tap their complianceofficers for help.

Unfortunately, we compliance peeps often serve up the usualanswer. It depends. Like it or not, that's usually thebest answer out there.

What topics? What training topics must youinclude in your training? Some are easier than others, such as BSA,which has a cleartraining requirement. Another clear example is the need for "Red Flags" training. But did you know that themost recent version of NCUA's model bylaws address training,indicating that a credit union's board must establish a policy toaddress training for newly elected and incumbent directors andvolunteer officials, in areas such as ethics and fiduciaryresponsibility, regulatory

compliance, and accounting. All of these training requirementsare sprinkled across various regulations and guidance documents.Check with your trade association, as they may have gathered alist. NAFCU has this training list (member log-in needed) available for itsmembers. But be careful relying on lists! Our list, for example,only tracks required or suggested training outlined by NCUA andother credit union regulators, such as FinCEN. Our list does not,for example, address HR training issues, such as sexual harassmenttraining. You're going to have to ultimately be responsible forcreating your own training program.

How much training? We get this question quite abit. "Will this training program satisfy NCUA's trainingrequirements?" That's a great question, but there's only one entitythat can ultimately answer that question. NCUA determines whether atraining program is adequate. For example, designing a BSA trainingprogram for volunteers is tricky. Do they get the same training asa teller? This guidancesays no.

The board of directors and senior management should beinformed of changes and new developments in the BSA, itsimplementing regulations and directives, and the federal bankingagencies' regulations. While the board of directors may notrequire the same degree of training as banking operationspersonnel, they need to understand the importance of BSA/AMLregulatory requirements, the ramifications of noncompliance, andthe risks posed to the bank. Without a generalunderstanding of the BSA, the board of directors cannot adequatelyprovide BSA/AML oversight; approve BSA/AML policies, procedures,and processes; or provide sufficient BSA/AML resources.(Emphasis added.)

The general rule of thumb is this: your people should get enoughtraining so they can fulfill their responsibilities. So yes,training should be tailored to the job function. Ugh. Noteasy.

Training format. Is there a required format?No. But I would think a good training program would incorporate inoffice, online, and out-of-office training components. Eachtraining format has its strengths and weaknesses. A good blendallows you to reach your trainees in different ways. You never knowwhat type of training will be the right one.

I probably disappointed some of you. If you were looking for thecomplete "training list," I do not have it. There is no such thingas a training "silver bullet" or "magic formula" in my humbleopinion. There is no model training policy that will work for everycredit union. Putting together a good training program takes a lotof hard work. But that shouldn't be a surprise. That's true formost important things in life.

Anthony Demangone is director of compliance for NAFCU andregularly blogs at www.nafcucomplianceblog.org