Gen Ops Flashcards
The two major requirements of the Bank Secrecy Act are….
Reporting requirements and record keeping requirements
When a member conducts a currency transaction that exceeds 10k the credit union has no duty to notify the member that it must file a CTR
True
CTRs must be e filed within how many days?
15
When a credit union looks at a members gov issued picture ID to verify identity, has it satisfied MIP requirement that credit union has a reasonable belief that it knows the true identity of the person?
Yes
What does a company have to do to receive a “payroll customer” exemption from CTR reporting requirements?
Company must have maintained a transaction account at the cu for at least two months, regularly withdraw over 10k in currency to pay employees, and be incorporated under US or state law
Can the “payroll customer” exemption be used for deposits?
No
What is the “special order geographic reporting requirement” of the BSA (section 5326)?
Nothing more than an order from the Treasury requiring filing of CTRs at a specific geographic location for transactions 10k or less
Who will the notice of the special order for geographic requirement be directed to?
Credit Union CEO
For geographic special order, will the notice outline the types of transactions that are subject to the order?
Yes
SARs must be filed for robberies and/or burglaries?
No
If a member pays for a cashier’s check or money order in amounts from 3k to 10k, the credit union must keep a record of what?
Member’s name, date of sale, amount, serial number, and type of instrument
Must credit union keep a log of transactions to purchase monetary instrument 3k to 10k made with cash?
No
What three things must a credit union BSA compliance program do?
Be in writing and be approved by board of directors, have ongoing training on the BSA for the credit union’s employees, and have independent testing for the credit unions compliance with the BSA’s requirements
True or false: the NCUA and regulations section 748.2 dealing with the BSA requirements for federal credit unions requires the credit union to file an annual report with the NCUA
False
Does the right to financial privacy act apply to all members of the credit union?
No
Does the right to financial privacy act apply to state and local government authorities?
No, only federal government authorities
What are the two main requirements of the Right to Financial Privacy Act?
General prohibition against disclosure and record keeping requirements
If a member grants a federal agency permission to examine her financial records, the permission form they sign must include a provision for financial compensation for any inconvenience to the member
False
If a member authorized the release of records to a federal agency in writing, the statement must specify the purpose for the release of information, the name of the agency to receive the info, and that the member has the right to receive a copy of the records that are released. Also the member can revoke the authorization
True
Are CTRs, SARs, 1099s, and bankruptcy claims exempt from RTFPA?
Yes
If federal agents demand a members info under an exception to the RTFPA, the cu should make sure the release comes under an exception (typically by contacting an attorney) before releasing the information
True
If cu receives an administrative subpoena or a judicial subpoena, the cu should not release any records until it receives a certificate of compliance
True
If feds present cu with a search warrant, the cu should release only the info described in the warrant
True
Under RTFPA records must be retained forever
True
When you sign an account card/form (substitute w9), you are certifying to the IRS that your name and SSN match, that you’re not subject to withholding, and that you are a us person
True
IRS considers mistakes what as errors on information returns (subject to penalty)?
Mistakes in SSN, address, last name, and dollar amount
A credit union that is required to apply withholding must notify member within 15 days after withholding begins
True
NCUA privacy regs define a member as an individual with a continuing relationship at the credit union
True
If a cu does not anticipate disclosing info to affiliates or non-affiliated third parties for marketing purposes, the cu is completely exempt from NCUA privacy regs
False
Verbal privacy notices are okay if member signs a statement acknowledging the receipt of the verbal notice
False
The cu does not anticipate disclosing info to affiliates or non-affiliated third parties for marketing purposes, the cu can provide a shortened, simplified notice
True
There are significant penalties and civil liabilities for CU for violating the NCUA privacy regs
False
Is staff training on the security program required per NCUA requirement for the credit unions member information security program?
Yes
What three things does NCUA guidance concerning electronic authentication program include?
Developing a process that is consistent and supports the credit unions overall security and risk assessment program, that is periodically reviewed, and that includes auditing and monitoring features
Under it’s data security response program, a credit union may contract with its service provider to notify all of its members and regulators that its information system has been breached
True
COPPA (children’s online protection program act) is a federal law enacted to prohibit unfair or deceptive Internet acts or practices in connection with the collection, use, and/or disclosure of personal information from and about children under the age of 13 who can access websites via the Internet
True
COPPA applies to a cu whose website can be merely accessed by children under 13
False
If cu plans to collect, use, and disclose personal info from children under 13, COPPA requires cu to have a website notice, a parental notice, and obtain parental consent
True
Prior to a member conducting business electronically, e-sign mandates that member be given an error resolution notice and procedures
False
Per e-sign how long is members affirmative consent good for?
Forever
CU must submit a request form detailing compliance with e-sign and NCUA or FRB before it can accept and rely on esignatures or engage in transactions sanctioned by the act
False
If cu files an ofac report it must retain report indefinitely
False (5 years)
If cu violates ofac it can lose NCUA insurance coverage
False
Ofac requires cus that have filed reports to conduct annual audits and file annual reports of blocked property
True
