ANSWERS(GRADED A+)
What are the five pillars of an effective BSA/AML compliance program? - ANSWER1.
Designation of a BSA compliance officer by the Board.
2. Provide for a system of internal controls to ensure ongoing compliance
3. Provide for independent testing to be conducted by credit union personnel or outside
parties
4. Provide training for appropriate personnel
5. Appropriate risk-based procedures for conducting ongoing member due diligence
True/False: The credit union's board of directors is ultimately responsible for the credit
union's BSA compliance? - ANSWERTrue
The BSA Officer must be knowledgeable of:
a. BSA, and related regulations
b. The credit union's products and services
c. The credit union's members
d. The credit union's neighborhoods
e. a&b
f. All of the above - ANSWERf. all of the above
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. - ANSWERFalse
Regulators recommend that independent test of your BSA program should be done:
a. Annually
b. Every 12 to 18 months
c. Whenever necessary
d. Before each exam - ANSWERb. Every 12 to 18 months
Who all is required to receive BSA/AML training? - ANSWERNew staff, BSA
Compliance Officer, Board of Directors, and all appropriate personnel
True/False: BSA/AML training should be tailored to the person's specific responsibilities
- ANSWERTrue
How often does BSA training need to be conducted? - ANSWEREvery 12 to 18 months
, What records of the BSA training program do credit unions need to keep? -
ANSWERRecords of training and testing materials, the dates of training sessions and
attendance records.
Which of the following products and services could possibly pose a higher risk for illegal
activities?
a. Wire transfers
b. Monetary instruments
c. Traveler's checks
d. All of the above - ANSWERd. All of the above
Section 326 of the USA Patriot Act requires financial institutions to: - ANSWER1.
implement reasonable procedures to verify the identity of any person seeking to open
an account
2. maintain records of the information used to verify the person's identity
3. determine whether the person appears on any lists of known or suspected terrorists
or terrorist organizations provided to the FI by any government agency
4. provide the member opening a new account with notice of the information collection
requirement.
A financial institution's CIP should be tailored to: - ANSWER1. it's size
2. location
3. types of accounts offered
4. methods of opening accounts; and
5. any other risk factors the FI believes affects its CIP procedures
What four pieces of information are credit union's required to collect on each new
member? - ANSWER1. name
2. address
3. date of birth
4. identification number
What are the two methods a credit union can use to verify identity? - ANSWER1.
documentary
2. non-documentary
What does the credit union's CIP procedures have to describe? - ANSWER1. 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.
True/False: the credit union must provide an adverse action notice if it refuses to open
an account based on a consumer report - ANSWERTrue
The identification and verification rules do NOT apply to which of the following?