In regards to policies and procedures, related to compliance training, is a bank responsible to provide the training to the vendor, or is the bank responsible to understand the training the vendor gives to their employees?

I believe it’s the latter. It is not that the bank is responsible for getting into the business of training its vendors, although I think that’s certainly permissible. At the end of the day, the vendor training needs to be sufficient, just as the bank needs to train its own employees. It’s sufficient to review the vendor’s training of its own employees to ensure that it covers all the correct bases. I don’t see anything in the guidance requiring otherwise.

Note: This transcript has been edited from the January 2015 vendor management webinar for clarity and completeness.

Answered By: Ben Olson