The Volcker Rule, designed to improve stability and accountability within the US financial system, changed on October 1st. LEO GRC’s Global Account Director, Stuart Meher, talks us through the changes and what you can do to get the best out of your Volcker training.
What Is the Volcker Rule?
The original Volcker Rule was designed to improve the stability of the US financial system and to prevent a recurrence of the 2008 financial crisis caused, in part, by excessive and irresponsible risk-taking at banks. On June 25, 2020, five leading US regulators approved amendments to the Volcker Rule. These amendments clarify and modify the prohibition on banking entities investing in or sponsoring hedge funds and private equity funds (referred to as Covered Funds). For your information, details of the amendments can be found here.
Volcker 2.0, as it has become known, took effect on October 1, 2020. Although it will provide significant opportunities for banks to take advantage of operational efficiencies and expand their permitted trading activities, the cost of non-compliance is very high. As a result, effective training will be a priority for impacted organizations, as well as an increased reliance on internal control and limits.
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The Training Challenge
Volcker 2.0 (and the original Volcker Rule) presents significant training challenges. The content is complex, highly technical, and global in impact. At LEO GRC, we have worked with a number of clients to update their Volcker training to meet the new requirements and to create new, effective Volcker 2.0 learning solutions. Here are our top tips for creating great Volcker 2.0 learning solutions.
Use Learner Diagnostics to Target Training
Use learner diagnostics to ensure that your training is targeted and tailored to your learners’ needs. This may mean, for example, including a pre-test so that those familiar with the Volcker Rule only receive summary content focusing on the impact of the changes on their role. It may also include a filter linked to role and global location so that each selected route through the course becomes a tailored learner journey.
Create Tailored Learner Journeys
Creating tailored learner journeys can be particularly helpful when navigating complex and technical content. They mean that the learner only sees content directly applicable to them and supports the creation of practical and immersive scenarios.
Related reading: ‘How to Motivate Your Learners Using Personalized Compliance Training’
Practical and Immersive Scenario-Based Training
Practical and immersive scenariosbring the complex and technical content to life. They help the learner to understand what they need to do differently in a range of situations that they are likely to face. This helps them to focus on behavioral change rather than technical concepts. Leading with practical and immersive scenarios means that the learning can be delivered through practical feedback.
More from the blog: ‘Engaging Compliance Training: It’s Time to Think Differently About Assessments’
Use a Glossary
The technical concepts cannot be avoided altogether. The use of a glossary helps lift the technical content off the page and enables the learner to use the glossary as an interactive learning tool. This will help to increase engagement in the learning, improve information retention, and lead to real behavioral change.
Monitor Learners’ Responses Through Data Analytics
We recommend using data analytics to monitor learners’ responses to in-line scenarios and assessments. The results can be used to generate follow-up, targeted learning interventions, if required, and to improve future versions of the course. Ultimately, measurement is a crucial part of creating an effective learner journey and to encourage continuous improvement of both the course content and the way it’s delivered.
Related reading: ‘Super Compliance and Impactful Analytics: How to Drive Sustainable Change’
With a lot of moving parts to consider, it’s important to find the right solution for Volcker 2.0 training. One of the major benefits of original digital content is that it can be changed and adjusted to your business needs and if/when the rules change again.
We have extensive experience in collaborating with clients to develop customized Volcker training that incorporates the core basic elements of and relevant amendments to the rule. While the rule was developed by US regulators, there are certain components that have an extraterritorial reach which adds a level of complexity to its applicability for institutions with a presence both within and outside of the US.
Our goal is to assist firms to meet the training challenges presented by the ever-changing regulatory environment and to develop training solutions that are insightful and promote the retention of knowledge and behavioral change. We create all of this with the goal of minimizing reputational risk and exposure to fines and penalties for non-compliance.