Is BSA Compliance Still on Your Radar Screen?

If BSA compliance has fallen off your radar in the wake of mortgage rules, remittance transfers and other issues it’s time to refocus. The NCUA recently issued a cease and desist order to North Dade Community Development Federal Credit Union of Miami Gardens, FL. Among other items, the credit union is required to complete the following.

  • Complete a comprehensive bank secrecy/anti-money laundering/foreign assets control risk assessment.
  • Revise and document board approval for all policies relating to bank secrecy, anti-money laundering, and foreign assets control.
  • Ensure staff and officials are adequately trained on all bank secrecy, anti-money laundering, and foreign assets control applicable laws and regulations.
  • Develop a system of internal controls to ensure ongoing compliance with all applicable bank secrecy, anti-money laundering, and foreign assets control laws and regulations.
  • Conduct bank secrecy, anti-money laundering, and foreign assets control compliance program testing.
  • Ensure bank secrecy, anti-money laundering, and foreign assets control testing is complete and results are reported to the board of directors.

Also noted in the cease and desist order is the requirement for the credit union to take care of issues related to their field of membership. Specifically,  the credit union must verify that all members are within the credit union’s field of membership. This is particularly of interest due to the recently issued Letter to Federal Credit Unions 13-FCU-03 that deals with aggressive marketing campaigns by federal credit unions to facilitate membership. We blogged about the letter earlier this week. Credit unions should take note of the continued look into BSA compliance programs and the potential for issues with membership.

You can read the full text of the letter here and read more about the BSA violations here.

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Federal Credit Union Membership Marketing

A letter to federal credit union’s regarding advertising campaigns that the NCUA has determined to be overly aggressive has recently been issued. In the letter, the NCUA specifically points out membership marketing campaigns that advertise a federal credit union as being “open to anyone”. The NCUA is concerned that this type of marketing gives the impression that there are no restrictions to join a federal credit union and that is not the case. The letter also describes the common bond requirements of the FCUA and the NCUA rules, advertising requirements and consequences for non-compliance.

Any federal credit union should take cation when advertising their membership eligibility to ensure it is not done in a manner that would appear to violate the either the NCUA rules or the FCUA.

For more information and to read the letter in its entirety, click here.

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Don’t Tax My CU Redux

It’s another “Don’t Tax My CU” Tuesday and this time around it is even easier to make your voice heard. Just log onto and send a message to your legislators. The site now provides pre-populated tweets and Facebook posts to assist you in supporting the credit union tax exemption.

The “Don’t Tax My CU” campaign has resulted in over 800,000 contacts with members of Congress.  Today’s event is especially important as members of Congress returned to Washington this week with budgets, among other things, on their minds.


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