Review of Mutuals’ Compliance with their Code Training Obligations

This inquiry examined whether customer owned banks are complying with their Code obligations to adequately train staff, agents and representatives in the Code’s requirements. We found that while most Code Subscribers have embedded Code training in their learning and development programs, the training content, method and frequency vary depending on the Code Subscriber’s size. We also found that some Code Subscribers need to improve their monitoring and supervision frameworks to ensure that their staff apply Code obligations in daily operations.