CORRECT Answers
True or False: False.
The credit union's BSA Officer is ultimately responsible for Although the BSA Officer is responsible for coordinating and monitoring day-to-
the credit union's BSA compliance. day BSA/AML compliance and managing all aspects of the BSA compliance
program, the credit union's board of directors is ultimately responsible for the
credit union's compliance. This is why it is critical that the board of directors
designate a qualified BSA officer and receive appropriate BSA/AML training
annually.
The BSA Officer must be knowledgeable of: The answer is F.
The BSA Officer is expected to be fully knowledgeable of the Bank Secrecy Act
A. The BSA, and related regulations; and all related regulations, as well as understand the money laundering and
B. The credit union's products and terrorist financing risks associated with the credit union's products, services,
services; members, and geographic locations of each credit union office and branch. The
C. The credit union's members; BSA Officer should be in a position to regularly apprise the senior management
D. The credit union's neighborhoods; staff and the board of directors of ongoing compliance with the BSA/AML
E. a & b requirements.
F. All of the above.
True or False: False.
If you are a small credit union (less than $100 million) it is As part of the credit union's internal controls, you must have policies and
acceptable to have the BSA Officer identify when BSA- procedures in place to limit and control risks associated with BSA/AML. Such
related reports must be filed, fill out the reports, and internal controls include the segregation of duties whenever possible, so that it
determine when members are eligible to be exempt from isn't the same person determining who is exempt from filing, when a report should
BSA reporting. be filed, and actually completing the reports. It is important to have a "checks and
balances" system in place.
,Regulators recommend that independent testing of your The answer is B.
BSA program should be done: The frequency of the required independent testing is not specifically defined in
the regulation, however, the regulators recommend that it be done every 12 to 18
A. Annually months, depending on the credit union's risk profile.
B. Every 12 to 18 months
C. Whenever necessary
D. Before each exam
Which of the following products and services may have a The answer is D.
higher risk for illegal activities? Although attempts to launder money or conduct other illegal activities through a
credit union can emanate from many different sources, certain products, services,
A. Wire transfers members, and geographic locations may be more vulnerable or have historically
B. Monetary instruments been known to be abused by money launderers and criminals. For example, some
C. Traveler's Checks products and services may allow a higher degree of anonymity ( such as
D. All of the above electronic funds payments), or involve the handling of high volumes of currency
(such as monetary instruments like cashier's checks, money orders, and traveler's
checks).
The identification and verification rules do NOT apply to The correct answer is "B."
which of the following? The CIP/MIP regulations apply to anyone applying to open an account, which
includes any accountholder on the account (members and non-members). This
A. Joint owners will include joint owners and trustees, as well as both resident and non-resident
B. Beneficiaries aliens. However, beneficiaries are not signers on an account and may not even
C. Co-borrowers know they are beneficiaries; therefore, they are not included on this list.
D. Non-resident aliens Additionally, the definition of "account" means any "formal banking or business
E. Applies to A, B, C & D. relationship established to provide an ongoing service, dealing, or other financial
transaction." This definition is broad enough to include loans, and therefore co-
borrowers would also fall under the requirements.
Yes or No: No.
Does the CIP/MIP rule prohibit a minor from opening an The CIP/MIP rule states that the credit union's "member" includes an individual
account? who opens the account for an individual who lacks legal capacity, such as a minor.
In other words, if a parent opens an account for a child, the member for purposes
of the CIP/MIP rule is the parent. If, however, a minor opens the account, then the
minor is the member. According to NCUA, when a minor opens the account,
he/she can be verified through documentary methods such as a driver's license or
work permit. If these are not available, the minor could be identified through
nondocumentary methods such as verification by an existing member, using
public databases, or verification of identity by parent/teacher. A credit union's
CIP/MIP policy must specify what types of documentary and/or non-documentary
evidence it will accept for a minor's account and the circumstances under which
such documentation will be acceptable.
Treasury explains that when a credit union sends its' employees to elementary
schools to allow students to open savings accounts as part of a program to
promote financial literacy, a student opening the account is the member and the
credit union must get the name, address, date of birth, and taxpayer identification
number of the student. Since verification procedures are risked-based, credit
unions can use any reasonable documentary or non- documentary method to
verify a student's identification.
, Yes or No: No.
Must a credit union verify the accuracy of all of the The regulation provides that a credit union's CIP/MIP must contain procedures for
identifying information it collects during the CIP/MIP verifying the identity of the member using the information obtained during the
process? credit union's CIP/MIP process. A credit union need not establish the accuracy of
every element of identifying information obtained, but must verify enough
information to form a reasonable belief that it knows the true identity of the
member.
Yes or No: Yes.
To satisfy the CIP/MIP record-keeping requirements, the The CIP/MIP regulation requires credit unions to retain the original information
credit union must retain the original information collected collected at the time of account opening for five years after the date the account
at account opening, in addition to updated information is closed. Obtaining and maintaining updated member information serves a
about the member (such as the member's current valuable, but different purpose.
address).
A non-profit organization wants to open an account at The correct answer is C.
the credit union. However, since non-profits do not have The regulation allows for some legal entities to be subject only to the "control
any "owners", it cannot provide "beneficial" owner criteria". Non-profit corporations, and similar entities, that have filed their
information. How can the credit union open this account? organizational documents with the appropriate State authority meet this
exception. This exception makes option (a) incorrect.
A. This account cannot be opened because the credit
union cannot verify identifying information from at least Option (b) is incorrect because none of the board members may own 25% or
one person who owns 25% or more of the legal entity. more of a non-profit organization. If one of the board members happens to have
B. The credit union can open the account by collecting a controlling position with the non-profit organization, the credit union could
the identifying information from at least one board open the account with this board member's identifying information to meet the
member to satisfy the "owner criteria"; "control criteria", but this board member will not meet the "owner criteria".
C. The credit union can open the account by collecting
identifying information from at one person who meets And finally, Option (d) is incorrect because non-profit organizations are legal
the "control" criteria; entities, and should have the state filing documents available to open the account.
D. The credit union can open the account because non-
profits are not legal entities.
True or False: False.
A Currency Transaction Report (CTR) is filed for every deposit, withdrawal,
A credit union must file a Currency Transaction Report payment, transfer, or other transaction involving CASH (currency) of more than
(CTR) if a member purchases $15,000 worth of traveler's $10,000.00. This includes any coin or paper money of the United States or of any
checks with a transfer from her checking account. other country. The purchase of cash equivalents or negotiable instruments like
traveler's checks do not trigger a filing of a CTR unless made with cash and
exceeds $10,000. This answer is false because the travelers' checks were paid for
by a transfer from the member's account.