In this excerpt, Justin Muscolino, GRC Solutions’ Head of Compliance Training in North America, explains how to develop a summary for your training needs analysis.
When creating your summary for a needs analysis, you need to understand the organizational goals and objectives as well as regulators’ expectations. In the financial industry there are several regulators, but your organization will only have a certain number depending on the products and services offered. Your summary should include which regulators are applicable and what products or services need to be covered.
Do your regulators require certain compliance training topics to be trained on? This should be identified in your summary, along with the relevant rules and regulations. In addition, organizational locations should be cited.
You will also need to identify how you will handle non-Full Time Equivalents (non-FTEs) in addition to existing staff. Will new hires, consultants, contractors and part-time staff be trained the same as FTEs or will there be a separate curriculum?
Lastly, you should outline the methodology that you adopt to perform our needs analysis. Is it a risk-based approach? If so, provide some details about your approach. For example: ‘a risk-based approach was used to identify the key risks within the organization, prioritizing the compliance training program around these risks.’
The summary should be detailed, providing an overall view of what and how you are targeting full compliance coverage through training.
The data derived from your needs analysis should be featured in your training plan. There should be a column devoted to acknowledging the sources from which the training entries originated (i.e. risk assessment, audit, or examination). This is covered in detail in the training plan section.
The key is to show a linkage throughout the process. If an audit or regulator conducts an examination, you will be able to show a detailed audit trail of each training entry.