BSACs Exam Prep Questions and Verified
Answers
Question 1
What should the procedures for indicating when to escalate issues or problems
identified as result of repeat SAR filings on accounts include?
Correct Answer
- review by senior management and legal staff
- criteria for when analysis of the overall member relationship is necessary
- criteria for when to close the account
- criteria for when to notify law enforcement, if applicable
Question 2
Up to how many number of individuals can be identified as beneficial owners under
the ownership and control prongs?
Correct Answer
Up to 4 individuals under the ownership prong
Only one individual under the control prong
Question 3
What does the credit union's CIP procedures have to describe?
Correct Answer
1. how the identity will be verified
2. when documentary methods, non-documentary methods, or a combination of
both methods will be used; and
3. what documents and non-documentary information the credit union will accept.
Page 1 of 25
,Question 4
What must the credit union do in order to get a member a CTR exemption?
Correct Answer
The credit union must file a one-time Designation of Exempt Person (DOEP) form
with FinCEN within 30 days after the first transaction in currency that the credit
union member wants to exempt.
Question 5
How long do credit unions have from the transmission date of the request to respond
to 314(a) requests?
Correct Answer
2 weeks
Question 6
Why must a CTR for deposits must list all joint owners on the account and not for
withdrawals?
Correct Answer
Because all joint owners have access to the funds at the moment they are
deposited.
Question 7
What is a "funds transfer"?
Correct Answer
A series of transactions, beginning with the originator's payment order, made for
the purpose f making payment to the beneficiary of the order.
Question 8
Does the CIP rule prohibit a minor from opening an account?
Correct Answer
No
Page 2 of 25
, Question 9
True/False: Some OFAC-administered programs will require a credit union to reject the
transaction altogether, rather than accept and freeze funds.
Correct Answer
True
Question 10
True/False: If you are a small credit union it is acceptable to have the BSA officer
determine when a CTR is necessary, fil out the CTRs, and determine who is eligible for
a CTR exemption.
Correct Answer
False
Question 11
What does a Phase II designation exempt?
Correct Answer
- non-listed businesses (those not listed on the stock exchange)
- payroll members
Question 12
What happens when a credit union blocks a transaction?
Correct Answer
It accepts the funds and freezes them so that the individual or entity cannot obtain
or recover possession of the funds
Question 13
How often must the credit union review the granted exemptions for both Phase I and
Phase II exemptions?
Correct Answer
Annually - to make sure the exemption is still appropriate
Page 3 of 25
Answers
Question 1
What should the procedures for indicating when to escalate issues or problems
identified as result of repeat SAR filings on accounts include?
Correct Answer
- review by senior management and legal staff
- criteria for when analysis of the overall member relationship is necessary
- criteria for when to close the account
- criteria for when to notify law enforcement, if applicable
Question 2
Up to how many number of individuals can be identified as beneficial owners under
the ownership and control prongs?
Correct Answer
Up to 4 individuals under the ownership prong
Only one individual under the control prong
Question 3
What does the credit union's CIP procedures have to describe?
Correct Answer
1. how the identity will be verified
2. when documentary methods, non-documentary methods, or a combination of
both methods will be used; and
3. what documents and non-documentary information the credit union will accept.
Page 1 of 25
,Question 4
What must the credit union do in order to get a member a CTR exemption?
Correct Answer
The credit union must file a one-time Designation of Exempt Person (DOEP) form
with FinCEN within 30 days after the first transaction in currency that the credit
union member wants to exempt.
Question 5
How long do credit unions have from the transmission date of the request to respond
to 314(a) requests?
Correct Answer
2 weeks
Question 6
Why must a CTR for deposits must list all joint owners on the account and not for
withdrawals?
Correct Answer
Because all joint owners have access to the funds at the moment they are
deposited.
Question 7
What is a "funds transfer"?
Correct Answer
A series of transactions, beginning with the originator's payment order, made for
the purpose f making payment to the beneficiary of the order.
Question 8
Does the CIP rule prohibit a minor from opening an account?
Correct Answer
No
Page 2 of 25
, Question 9
True/False: Some OFAC-administered programs will require a credit union to reject the
transaction altogether, rather than accept and freeze funds.
Correct Answer
True
Question 10
True/False: If you are a small credit union it is acceptable to have the BSA officer
determine when a CTR is necessary, fil out the CTRs, and determine who is eligible for
a CTR exemption.
Correct Answer
False
Question 11
What does a Phase II designation exempt?
Correct Answer
- non-listed businesses (those not listed on the stock exchange)
- payroll members
Question 12
What happens when a credit union blocks a transaction?
Correct Answer
It accepts the funds and freezes them so that the individual or entity cannot obtain
or recover possession of the funds
Question 13
How often must the credit union review the granted exemptions for both Phase I and
Phase II exemptions?
Correct Answer
Annually - to make sure the exemption is still appropriate
Page 3 of 25
