This training requirement applies to companies that regularly employ (or contract to employee) at least fifty (50) employees.  The 50 employees do not all have to be located in California.  The California Code of Regulations [2 Cal Code Regs 11024 (a) (8)], defines “supervisory employee” as any individual with authority to hire, transfer, suspend, layoff, promote, discharge, assign, reward or discipline other employees.  It is a fairly broad definition that includes the concept of independent judgement as a requirement for job performance.

The training must be done by trainers or educators with particular expertise in this area and must deal with a variety of modalities, such as classroom training, e-learning with links to “live trainers” and webinars.  The covered topics are specifically described under 2 Cal Regs Section 11024 (a) (2) and include the following.

1. Information and guidance on federal and state law concerning the prohibition and prevention of harassment;
2. Information on correction of the problem and available remedies and
3. Examples drafted to suggest how supervisory employees are to prevent, harassment, discrimination, retaliation and abuse in the workplace environment.

The advice I have given to my bank, mortgage companies and specialty lending firms clients is that now is a good time to review and upgrade compliance training programs.  This compliance update process must include all necessary corporate and regulatory compliance changes, including, but not limited to revising employee manuals and looking at ways the compliance information is kept and disseminated within the company.  I have also advised my clients that training in profit centers such as loan documentation, etc. can also help to minimize risk in the institution.

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