Bank Secrecy Act & Treasury BSA Regulations

Question 1

What are the two major requirements of the Bank Secrecy Act and regulations.

Answer 1

Reporting and Recoding keeping
CTRS and SARS
MIP and BOR (Beneficial Ownership Rule)

Question 2

T or F
When a member conducts a currency transaction that exceeds $10,000, the credit union has no duty to notify the member that it must file a Currency Transaction Report (CTR)

Answer 2

True

Question 3

T or F
Multiple same day currency transactions conducted by or on behalf the same person must be added together and reported on a CTR if the cash transactions exceed $10,000.

Answer 3

True

Question 4

T or F
CTRs must be e-filed within 15 days.

Answer 4

True

Question 5

T or F
When a credit union looks at a member’s government issued picture ID to verify the member’s identity that satisfies the MIP’s requirement that the credit union has a “reasonable belief that it knows the true identity of the person

Answer 5

True

Question 6

T or F
Under the MIP the credit union is required to obtain the physical address of a new member opening an account.

Answer 6

True

Question 7

T or F
In order to receive a “payroll customer” exemption from the CTR reporting requirements, a company must have maintained a transaction account at the credit union for at least two months, regulary withdraw over $10,000 in currency to pay employees, and be incorporated under US or state laws

Answer 7

True

Question 8

T or F
In order to receive a “payroll customer” exemption from the CTR reporting requirements, a company must have maintained a transaction account at the credit union for at least two months, regularly withdraw over $10,000 in currency to pay employees, and be incorporated under US or state laws.

Answer 8

True

Question 9

T or F
Can the “payroll customer” exemption be used for deposits as well?

Answer 9

False

Question 10

T or F
The “special order geographic reporting requirement” of the Bank Secrecy Act (a section 5326 order), is nothing more than an order from Treasury requiring the filing of Currency Transaction Reports (CTRs) at a specified currency transaction threshold of $10,000 or less

Answer 10

True

Question 11

T or F
When the Treasury Department orders “geographic targeting” 1. the dollar threshold for filing CTRs may be lower than the normal threshold amount, 2. the notice of the special order will be directed to the credit union’s CEO, and 3. the notice will outline the types of transactions that are subject to the order.

Answer 11

True

Question 12

T or F
A Suspicious Activity Report (SAR) must always be filed in the case of a robbery?
What about a burglary?

Answer 12

False and False

Question 13

T or F
When a member wishes to pay cash for (i.e. purchase) an instrument such as a cashier’s check or a money order in amounts from $3000 to $10000, the credit union must keep a record of the member’s name, date of sale, amount, serial number and type of instrument.

Answer 13

True

Question 14

T or F
BSA statues require the credit union to keep a log of these transactions.

Answer 14

False

Question 15

The credit union’s Bank Secrecy Act compliance program must

Answer 15

1. Be in writing and approved by the board of directors
2. have ongoing training on the BSA for the credit union’s employees
3. have independent testing for the credit union’s compliance with the BSA’s requirements

Question 16

T or F
The NCUA Rules and Regulations Section 748.2 dealing with the bank secrecy requirements for federal credit unions requires the credit union to file an annual report with the NCUA.

Answer 16

False