Last month, we asked how you train your employees to process loan requests from employees. Your responses show a keen understanding of how to provide training on Regulation O. This month, we want to know how you protect your customers’ information from vendors who work in your building. How do you build trust while safeguarding your important data? We need your best advice.

We also invite you to take our 5-minute survey to help us understand what compliance issues your institution is most concerned with and what management solutions are most needed to help ease the burden. Everyone who completes the survey will be entered in our drawing to win an Apple iPod™.

The vice president of our bank is starting a side business in our community. He has approached our loan department to apply for a small business loan. While I know this request is perfectly ethical, I also know Regulation E makes it very clear how this type of loan should be approved.

Has anyone else approved a business loan to a bank employee? What are some of the processes that you followed? How are other banks training their employees on Regulation O?

—Janice K., Loan Officer

The employees at our bank receive extensive training on handling confidential information. I am worried, though, about the level of training that our vendors receive. Some of them have access to a great deal of customer information, especially during off-hours, without much supervision.

I am not as worried about the vendors we use to maintain our computers and network. I am thinking more about our cleaning staff, our groundskeepers and other vendors that might have a higher rate of turnover.

How can I build trust with these vendors while still ensuring that our customer information will be safe? How should I train our own employees to monitor vendors, without appearing overly suspicious?

— Alan F., Compliance Officer