Your Prescription for a Healthy Credit Union

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    It’s often difficult for credit union executives to find the time to go through a quarterly or annual risk management review process, or to ensure the credit union is in compliance. Keeping up with the new regulations or changes can be a daunting task. CU Rx works solely with credit unions providing the expertise to ensure they meet regulatory requirements and improve overall risk management. That's why you should contact CU Rx today.

Audit Policy Procedure

Credit unions are required to write numerous policies and procedures to ensure compliance with rules and regulations, and to document adequate internal controls. Laws and regulations that govern your credit union are constantly changing which can lead to inadvertent non-compliance if you fail to adapt your policies.

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    CU Rx will conduct a comprehensive analysis of your internal policies and related procedures to determine the current level of compliance and, if necessary, suggest changes to policies and procedures to ensure compliance. The list below is not all inclusive and can be adapted based on your credit union's needs. Your credit union identifies the policies and procedures you would like reviewed.

    Policies that may be included in the review include:

    • ACH Policy + Business Lending Policy
    • General Lending Policy
    • New Account (CIP) Policy
    • Overdraft Protection Policy
    • Real Estate Construction Policy
    • Security Program (Section 748 Compliance) + Truth in Savings
    • Wire Policy
    • Bank Secrecy Act Policy + Collection Policy
    • Indirect Lending Policy + New Member Disclosures
    • Privacy (GLBA)
    • Regulation (ClExpedited Funds Availability + Truth in Lending
    • Website Compliance Policy

ID Theft Red Flags Training

The National Credit Union Administration (NCUA), Federal Trade Commission (FTC) and other financial institution regulators issued joint guidance requiring each financial institution or creditor to develop and implement a written ldentity Theft Prevention Program to detect, prevent, and mitigate identity theft in connection ...

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    ...with the opening of certain accounts or certain existing accounts. The implementing rules also require credit and debit card issuers to assess the validity of notifications of changes of address under certain circumstances. Summarily, the joint rules provide guidance regarding reasonable policies and procedures that will help identify "red flags," which are patterns, practices, or activities that indicate the possible risk of identity theft, along with rules requiring financial institutions and other creditors to implement the guidelines.

    The guidelines list a number of"red flags” including:

    • The existence of fraud alerts
    • Altered and inconsistent information
    • Account use that fits a pattern of fraud
    • Notifications of unauthorized charges or fraudulent account charges Attempts to access accounts by unauthorized users

    The rules allow for a risk-based, flexible approach that requires financial institutions and creditors to develop a program that is appropriate to the size and complexity of the institution, as well as the nature and scope of its activities.

Bank Secrecy Act Audit

A vital and mandatory component to a Bank Secrecy Act (BSA) compliance program is the provision for independent testing or auditing to ensure compliance. Whether performed by internal or external staff, an effective audit plays an important role in independently evaluating risk management, controls and effectiveness ...

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    ... of compliance with BSA/AML/OFAC. Policy statements alone are not sufficient; practices must coincide with the credit union's written policies, procedures and processes. Credit Unions must establish and maintain a written compliance program for fulfilling the requirements of the Bank Secrecy Act (BSA) that includes at least:

    1. 1. A system of internal controls
    2. Designation of an individual to coordinate/monitor BSA compliance
    3. Independent testing
    4. Training of appropriate personnel.

    In addition, an effective BSA compliance program should include written policies and procedures designed to detect and prevent money laundering activities. CU Rx will assess the effectiveness of the credit union's BSNAML compliance program and the credit union's compliance with BSA regulatory requirements, including a review of risk management practices.