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19. E-Banking Compliance Policy and Procedures 20. E-Commerce Risk Assessment See Also, Information Security Below 25. Fair Credit -- Equal Credit Opportunity Act (ECOA) Policy and Procedures 26. Fair Credit Reporting Act Policy and Procedures 28. Risk Assessment of Insurance and Bond Coverage per Credit General – NCUA Letters to Credit Union Nos. 02-FCU- 17; 97-FCU-05 and 97-FCU-05a (Authentication) -- 05- FCU-18 See Also, Information Technology and Information Security Addressed via either Policies and/or Procedures as the Credit Union chooses. However, the elements addressed in the foregoing must be addressed. Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 No Further Comment. NCUA Letter to Credit Union No. 06-FCU-13 – Risk Assessment Required; NCUA Letter to Credit Union No. 01-FCU-12 (and to inform the Board of the Risk Assessment). See also FFIEC Guidelines. This includes an insurance risk assessment to include all high risk areas. NCUA Letter to Credit Union No. 02-CU-08 (Re: Account Aggregation) – and OCC Bulletin 2001-12 Recommend a General Statement of Policy in Credit Union’s General Loan Policy. See Recommendations in the Section Above on a Compliance Policy NA – Red Flags and Identity Theft are addressed separately below. It is our recommendation to have complete FCRA Policy/Procedure as “Red Flags” standing alone does seems incomplete. NA NA – Red Flags and Identity Theft are addressed separately below. Appropriate Procedures are recommended tools to insure compliance with the complex laws that govern this area – and to protect against violations of such laws -- noncompliance with which may subject the Credit Union to significant damage claims. Appropriate Procedures are recommended tools to insure compliance with the complex laws that govern this area – and to protect against violations of such laws -- noncompliance with which may subject the Credit Union to significant damage claims. These may incorporate Red Flags and Identity Theft for consistency, which we also recommend. NCUA Rules and Regulations: 12 CFR 713.5; NCUA Field Examiner’s Guide – Chapter 6 – Appendix A (Page 6A-6) 34
Union Assessment 33. Identity Theft Policy and Procedures // Red Flags Policies - Procedures 34. Red Flags Risk Assessment 12 CFR 717.82 and 717.91; and NCUA Letter to Credit Union No. 08-FCU-24 // Policies and Procedures are required See Prior Entry – Properly drafted with supporting forms – these procedures may provide additional liability protection for the Credit Union and its Volunteers / Senior Management Annual – Must be Approved by the Board or a designated Board Committee 36. Incident Response Policy and Procedures 39. Information Security and Information Technology Policies and Procedures; Internet Use Policy and Procedures 40. Information Technology Security Risk Assessment 43. Risk Assessment of Investments 12 CFR 717.82 and 717.91; and NCUA Letter to Credit Union No. 08-FCU-24 // Policies and Procedures are required in part by the same laws governing Identity Theft and Red Flags 12 CFR 748 and Appendices NCUA Letter to Credit Union Nos. 06-FCU-10 06- FCU-06; 03-FCU-07 General IT – FFIEC Guidance; 03-FCU- 14; 03-FCU-06; Personnel and Responsibilities for IT and Patch Management; 01- FCU-11- Electronic Data Security; 99- FCU-19 – Monitor for Security Intrusions; 06-FCU-07 E-Banking Security; 00-FCU-02 Background Checks; 03-FCU-08 Weblinking Risks (See also 02-FCU-04); 03- FCU-08 Wireless Technology; 05-FCU- See Prior Entry -- Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 NA Properly drafted with supporting forms – these procedures may provide additional liability protection for the Credit Union and its Volunteers / Senior Management See NCUA Letter No. 02-FCU-08 Re: “account aggregation services.” 20 Phishing NCUA Letter to Credit Union No. 06-FCU-13 – Risk Assessment Required; NCUA Letter to Credit Union No. 01-FCU-12 (and to inform the Board of the Risk Assessment) NCUA Rules and Regulations: 12 CFR 748.and Appendices; 12 CFR 749.and Appendix B NCUA Rules and Regulations: 12 CFR 703.13(c)(1) and (e)(2); NCUA Field Examiner’s Guide – Chapter 12 35
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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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EMPLOYMENT AGREEMENT Revise to addr
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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
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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
Page 57 and 58: and other relatives who live in the
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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
Page 67 and 68: A Review of ‘Red Flags’ and wha
Page 69 and 70: Business Depositors: Understanding
Page 71 and 72: WHAT POLICIES, PROCEDURES AND RISK
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Page 77 and 78: Procedures 60. Training Policy See
Page 79 and 80: Also - consider the other changes c
Page 81 and 82: policies, procedures and documents
Page 83 and 84: Underwriting Advertising In July 20
Page 85 and 86: 135-2009 Community Notice // OE/CE
Page 87 and 88: Credit Union’s lien right are not
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