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Membership? Matters to Address: FOM and Bylaws BSA/CIP IRS Code – TIN or EIN Risk Assessment (MSBs and Other Issues … What Documents? What and From Where Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 30
WHAT POLICIES, PROCEDURES AND RISK ASSESSMENTS ARE WE REALLY REQUIRED TO HAVE? AND WHAT SOULD IT HAVE? Policies, Procedures and Assessments Many Credit Unions are confused by the myriad “requirements,” advice, rules, regulations, instructions as to what policies, procedures and assessments it is required to implement and maintain. (Out of Date Matters Such as Y2K Related issues; and Items that are replaced by more current standards (Example: 1989 NCUA Letter on Technology Matters) are omitted from this Resource as not being applicable). To help I provide the following chart that provides: NOTE ONE: Generally, procedures are recommended in most instances based upon various legal liability and compliance considerations. Thus, the third column below is used for emphasis on areas where we consider such to be of particular importance. When properly drawn – and when combined with proper forms, procedures and other related tools – Credit Union procedures may provide a great deal of protection from liability claims and potential regulatory fines. NOTE TWO: References are to General Federal Laws / Regulations or to NCUA Regulatory Alerts, Letters to Credit Unions; Supervisory Letters; and the NCUA Field Examiners Guide. References are only to Active NCUA Resources. Retracted or Inactive Letters have not been used in this assessment. Policy / Procedure / Assessment Board Policy or Approval Required (as to Assessment and/or Procedures) Generally -- Left to Credit Union/Management – Board Approval or Assessment Generally Not Required NOTES and/or Recommendations per Legal / Compliance or as a Significant Liability Protection Tool 1. Bank Secrecy Act 12 CFR 748, 31 CFR 103 (Primary Regulation) - The Law states that the general BSA/AML program is to be Approved by the Board. The Board also appoints the BSA Officer. NOTE A. 2. Bank Secrecy Act Risk Assessment For the most part the day-to-day procedures are addressed in several procedures; and via the Credit Union training materials and record of training. NOTE B. Must be presented to and approved by the Board. NOTE C. No Further Comment. Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 31
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Compliance Update - I REGULATORY AN
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Introductory Notes: Basic Obligatio
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performed by boards of directors. T
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What if an applicant “volunteers
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Please answer the following questio
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MULTIPLE ISSUES AND RESOURCES - SOM
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• Review of the negative shares r
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illustrates how certain provisions
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SAMPLE CREDIT UNION BUSINESS PLAN M
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Page 37 and 38: PRIVACY - INFORMATION SECURITY Priv
Page 39 and 40: Disposal of Consumer Reports and Ot
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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
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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
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Page 67 and 68: A Review of ‘Red Flags’ and wha
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