Good morning,
My team has the following questions regarding how others are handling dual control and training.
Question: Do you train your staff in-house on dual control (roles and responsibilities) or do you send employees with dual control responsibilities to outside training? The examiners guide says that personnel must understand control procedures and follow them conscientiously. If one of the individuals with dual control is in a position of authority over the other individual, how do you help ensure that each individual understands their role and responsibility to hold the other accountable if they do not act with prudence or within the confines of the designed procedures? Without the proper training and understanding, I can see where the person without authority would trust the judgement of the one with authority, which could lead to problems. Policies and procedures and holding people accountable are all great, but I think the training and acceptance of such a role is also very important. I'm interested in what others are doing to address this.
Question: For those of you using TCRs in your branches, how is dual control documented? We have a log for the vault cash, but the TCR only requires one login. Does anyone have a TCR that accepts two logins (one to load the cash and one to confirm it)?
Thanks,
Nabila Sheikh
Operational Risk Officer
NASA Federal Credit Union
