Multiple monetary instrument purchases during one One purchase when instruments total $3,000 or more
business day are treated as______ _.
3 multiple choice options
True or False: The credit union's BSA Officer is ultimately False. The credit union's board of directors is ultimately responsible for the credit
responsible for the credit union's BSA compliance. union's compliance.
The BSA Officer must be knowledgeable of: All of theses
3 multiple choice options
True or False: If you are a small credit union (less than False. As part of the credit union's internal controls, you must have policies and
$100 million) it is acceptable to have the BSA Officer procedures in place to limit and control risks associated with BSA/AML.
identify when BSA-related reports must be filed, fill out
the reports, and determine when members are eligible to
be exempt from BSA reporting.
Regulators recommend that independent testing of your Every 12 to 18 months
BSA program should be done:
3 multiple choice options
Which of the following products and services may have a All of the these
higher risk for illegal activities? 3 multiple choice options
The identification and verification rules do NOT apply to Beneficiaries
which of the following?
3 multiple choice options
, Yes or No: Does the CIP/MIP rule prohibit a minor from No. The CIP/MIP rule states that the credit union's "member" includes an individual
opening an account? who opens the account for an individual who lacks legal capacity, such as a minor.
Yes or No: Must a credit union verify the accuracy of all No. The regulation provides that a credit union's CIP/MIP must contain procedures
of the identifying information it collects during the for verifying the identity of the member using the information obtained during the
CIP/MIP process? credit union's CIP/MIP process.
Yes or No: To satisfy the CIP/MIP recordkeeping Yes. The CIP/MIP regulation requires credit unions to retain the original
requirements, the credit union must retain the original information collected at the time of account opening for five years after the date
information collected at account opening, in addition to the account is closed.
updated information about the member (such as the
member's current address).
A non-profit organization wants to open an account at The credit union can open the account by collecting identifying information from
the credit union. However, since non-profits do not have at one person who meets the "control" criteria.
any "owners", it cannot provide "beneficial" owner 3 multiple choice options
information. How can the credit union open this account?
What are the 5 pillars of the BSA/AML Compliance A Qualified BSA Compliance Officer, System of Internal Controls, Independent
Program? testing, Training for all appropriate personnel, and Ongoing member due
diligence.
True or False: A credit union must file a Currency False. The travelers' checks were paid for by a transfer from the member's account.
Transaction Report (CTR) if a member purchases $15,000 The purchase of cash equivalents or negotiable instruments like traveler's checks
worth of traveler's checks with a transfer from her do not trigger a filing of a CTR unless made with cash and exceeds $10,000.
checking account.
True or False: A member writes three checks (one check False. In this case, one person is not cashing the checks and, unless the credit
each) to three different people. The total amount of the union has knowledge otherwise, it has to assume the three individuals cashing the
three checks exceeds $10,000. Each payee cashes his or checks are not acting on behalf of the check-writer.
her check at the credit union on the same day. The total
amount of cash that is withdrawn from the member's
account in one day is more than $10,000. Under these
circumstances, a credit union must file a Currency
Transaction Report (CTR).
Yes or No: The compliance officer at the credit union Yes. In cases where 15 day deadline was missed, the CTR should be prepared with
learned during an audit that a member made a $15,000 the reason(s) for delinquency documented.
cash deposit at the teller lane but no Currency
Transaction Report (CTR) was filed. The transaction
occurred over two months ago. Should the form be filed?
Yes or No: A member deposited $9,000 in cash at the No. When aggregating cash transactions for the purpose of filling out a currency
credit union in the morning, and later that day withdrew transaction report (CTR), you must consolidate deposits (Cash In) and withdrawals
$3,000 in cash from an ATM. Is a CTR required? (Cash Out) separately.
Yes or No: Does a CTR need to be filed when you know a No. You do not need to file a CTR in this situation because no "transaction" has
member is placing more than $10,000 in a Safe Deposit occurred. However, if the situation feels suspicious to you, you may consider
Box? filling out a suspicious activity report (SAR).