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SAMPLE MINUTES Initial Board or Designated Committee of Board Adoption of Red Flags Assessment and Credit Union Red Flags Policy/Procedures – 12 CFR 717.90 Drafting Notes are in RED --- Add/Revise to Minutes or by way of a resolution (Example – Craft to suit adoptions and/or future revisions as needed): Who must approve the Assessment and the Policy/Procedures: 12 CFR 717.90(e) requires [“Each federal credit union must] … (1) Obtain approval of the initial written Program from either its board of directors or an appropriate committee of the board of directors. __________________________ (name of person or committee) the __________________________ (Officer such as Manager, CEO, Compliance Officer, etc., or describe committee) presented the Credit Union’s risk assessment of “covered accounts” described in 12 CFR 717.90(b)(3)(ii), taking into consideration: (1) The methods it provides to open its accounts; (2) The methods it provides to access its accounts; and (3) Its previous experiences with identity theft. The Board/Committee has received appropriate training and information on the Credit Union’s duties and obligations regarding the detection, prevention, and mitigation of identity theft in order to properly assess the issues set forth herein; and to approve of the Credit Union’s Policy/Procedures. Approval of Assessment of “Covered Accounts.” The Board/Committee approves the Credit Union’s risk assessment as presented and finds it to be appropriate pursuant to the size and complexity of the Credit Union and the nature and scope of the Credit Union’s activities. Approval of the Credit Union’s Identity Theft Prevention Program. The Board/Committee approves of the Credit Union’s Policies and Procedures dated as of the date of this resolution and finds that the Policies and Procedures: (1) Identify relevant Red Flags for the “covered accounts” that the Credit Union offers or maintains, and incorporates said Red Flags into its Policies/Procedures; (2) Provide for appropriate methods/procedures to detect identified Red Flags that have been incorporated into the Policies/Procedures of the Credit Union; (3) Provide Procedures to respond appropriately to any identified Red Flags that are detected pursuant to the Credit Union’s Policies/Procedures; and (4) The Credit Union’s Policies/Procedures provide for appropriate periodic auditing, assessment and updates to reflect changes in risks to members and the Credit Union as appropriate to the risk assessment and the safety and soundness of the Credit Union relating to or arising from potential identity theft. (5) Provide proper controls and assessment of third parties including Credit Union vendors and service providers pursuant to these policies and the Credit Union’s Vendor Management Policies/Procedures. The board of directors approved the Identity Theft Risk Assessment and the Credit Union’s Policies/Procedures this ______________________. Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 16
SAMPLE CREDIT UNION BUSINESS PLAN Most of this Plan is Omitted Management Plan — Directors and Officers A. Provide the number of organizers and/or directors. Provide a list of board committees and a brief explanation of the responsibilities of each committee. B. Describe the organizational structure and provide an organizational chart, indicating the number of officers and employees. Describe the duties and responsibilities of the senior executive officers. Describe committees that are or will be established. C. Discuss the credit union’s plans to address management succession, including a management training program. Financial Management Plan A. Capital and Earnings 1) Discuss the capital goals and the means to achieve them. Include amount of ownership shares purchased by each provisional director, and the anticipated total amount of ownership share capital as of the formation of the credit union. 2) Discuss the earnings goals in terms of return on assets, net interest margin, or other profitability measurements, and summarize the strategies to achieve those goals. 3) Discuss the plan for raising capital and for financing growth, with particular emphasis on conformance with regulatory capital requirements. 4) Discuss the adequacy of the proposed capital structure relative to internal and external risks, planned operational and financial assumptions, including technology, branching, and projected organization and operating expenses. Present a thorough justification to support the proposed capital. B. Liquidity and Funds Management C. Sensitivity to Market Risk Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 17
Page 1 and 2: Compliance Update - I REGULATORY AN
Page 3 and 4: Introductory Notes: Basic Obligatio
Page 5 and 6: performed by boards of directors. T
Page 7 and 8: What if an applicant “volunteers
Page 9 and 10: Please answer the following questio
Page 11 and 12: MULTIPLE ISSUES AND RESOURCES - SOM
Page 13 and 14: • Review of the negative shares r
Page 15: illustrates how certain provisions
Page 19 and 20: EMPLOYMENT AGREEMENT Revise to addr
Page 21 and 22: 13. Evaluate the job performance of
Page 23 and 24: 2. By Employer For No Cause. Employ
Page 25 and 26: Vendor Due Diligence II Security As
Page 27 and 28: Vendor Due Diligence VII TERM AND T
Page 29 and 30: Vendor Due Diligence XII Backgroun
Page 31 and 32: Monitoring the Vendor At a minimum,
Page 33 and 34: NOTE: The BSA also contains a “wh
Page 35 and 36: (5) Confidentiality of reports. SAR
Page 37 and 38: PRIVACY - INFORMATION SECURITY Priv
Page 39 and 40: Disposal of Consumer Reports and Ot
Page 41 and 42: Compliance Update - II REGULATORY A
Page 43 and 44: Introductory Notes: Knowing if you
Page 45 and 46: I. POLICY AND GUIDELINES Portions O
Page 47 and 48: any CUSO. [Gifts may not be accepte
Page 49 and 50: Conference and Seminar Costs Fees f
Page 51 and 52: We have stated that there must be a
Page 53 and 54: IV. POLICY REGARDING CONFLICTS OF I
Page 55 and 56: public, even though, such relatives
Page 57 and 58: and other relatives who live in the
Page 59 and 60: protection, and the reimbursement o
Page 61 and 62: Legal / Compliance Consultation Not
Page 63 and 64: MERGER AND CONSOLIDATIONS ISSUES NO
Page 65 and 66: information of which unauthorized d
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A Review of ‘Red Flags’ and wha
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Business Depositors: Understanding
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WHAT POLICIES, PROCEDURES AND RISK
Page 73 and 74:
16. Conflict of Interest/Code of Et
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Union Assessment 33. Identity Theft
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Procedures 60. Training Policy See
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Also - consider the other changes c
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policies, procedures and documents
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Underwriting Advertising In July 20
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135-2009 Community Notice // OE/CE
Page 87 and 88:
Credit Union’s lien right are not
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