CERTIFICATION EXAM PREP WITH COMPLETE REAL
EXAM QUESTIONS AND CORRECT VERIFIED
ANSWERS/ ALREADY GRADED A+ (MOST RECENT!!)
Some requirements of the MDD are similar to the CIP requirements.
What additional requirements does MDD require credit unions to do?
1. gain an understanding of the nature and purpose of member
relationships and under your member's normal and expected
transaction activity, based on their occupation or business operations,
so that you can better determine if something is suspicious, and whether
a SAR needs to be filed;
2. keep an eye out for indicators of potential changes in the member's
risk profile, for example a change in employment, a change in business
operations, or unexpected account activity;
3. include procedures to periodically monitor your member's
information
4. on a risk basis, maintain and update member information - including
information regarding the beneficial owners of legal entity members.
How does the CDD/MDD rules define "legal entity"?
The rule defines a "legal entity" as a corporation, LLC, or other entity
that is created by the filing of public document with a Secretary of State
or similar office; a general partnership or similar entity.
What are considered NOT legal entities?
sole proprietorships, unincorporated associations, or natural persons
opening accounts on their own behalf
,What entities are only subject to the control criteria prong in the
definition of "beneficial owner"?
1. any legal entity that is established as a non-profit corporation or
similar entity and has filed its organizational documents with the
appropriate State authority;
2. any legal entity only to the extent that it opens a private banking
account subject to BSA requirements;
3. any pooled investment vehicle that is not exempt.
What are the two prongs that the CDD/MDD rules defines as "beneficial
owner"?
Ownership criteria and Control criteria
What are the ownership criteria under the definition of the beneficial
owner?
Each individual, if any, who directly or indirectly, through any contract
arrangement, understanding, or otherwise, owns 25% or more equity in
the legal entity
, What is the control criteria under the definition of beneficial owner?
A single individual with significant responsibility to control, manage, or
direct the legal entity, such as CEO, CFO, VP or other member of the
senior management team or a person that regularly performs similar
functions.
Up to how many number of individuals can be identified as beneficial
owners under the ownership and control prongs?
Up to 4 individuals under the ownership prong
Only one individual under the control prong
Is the credit union permitted to require a lower ownership threshold
(less than the 25%), thus making it more likely for an owner to meeting
the beneficial ownership criteria?
Yes; it is encouraged for higher-risk entities
What are the 3 ways a credit union can identify the beneficial owners of
business accounts?
1. by obtaining a "Certification Regarding Beneficial Owners of Legal
Entity Customers" provided in the rule;
2. by using the credit union's own forms, as long as they meet the
requirement in the rule; or
3. by obtaining the required information by any other means - provided
the person opening the account and providing the information certifies
that it is accurate.