What are the two prongs that the CDD/MDD rules defines as "beneficial owner"? -
CORRECT ANSWER-Ownership criteria and Control criteria
What are the ownership criteria under the definition of the beneficial owner? -
CORRECT ANSWER-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? - CORRECT
ANSWER-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? - CORRECT ANSWER-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? -
CORRECT ANSWER-Yes; it is encouraged for higher-risk entities
What are the 3 ways a credit union can identify the beneficial owners of business
accounts? - CORRECT ANSWER-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.
What should be included in the verification of beneficial owners procedures? -
CORRECT ANSWER-1. when the credit union should no open an account
2. the terms under which a legal entity member may use an account while the CU
attempts to verify the beneficial owner's identity
3. when you will close an account, after attempts to verify a member's identity have
failed; and
4. when you should file a SAR
Can a credit union rely on information in its possession to fulfill the identification and
verification requirements of a beneficial owners that is an existing member of the CU? -
CORRECT ANSWER-Yes
, 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 - CORRECT ANSWER-f. 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. - CORRECT ANSWER-False
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 - CORRECT ANSWER-b. Every 12 to 18 months
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 - CORRECT ANSWER-d. All of the above
Section 326 of the USA Patriot Act requires financial institutions to: - CORRECT
ANSWER-1. 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: - CORRECT ANSWER-1. 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? - CORRECT ANSWER-1. name
2. address
3. date of birth