21-Day Fix on to President’s Desk; Reg Z Proposal: Timely Settlement of Estates
Posted: 29 Oct 2009 11:08 PM PDT – NAFCU Compliance
Update by Anthony Demangone 7:55 p.m., Thursday evening
I just received an email from our lobbying dynamo, Brad Thaler. Just minutes ago, the U.S. Senate passed H.R. 3606 by unanimous consent. This bill would make a technical correction to the Credit CARD Act to limit the 21-day requirements to credit cards, instead of all open-end lending. The legislation now goes to President Obama’s desk. He is expected to sign it within days.
Many thanks to all of you for your help in getting this legislation to this point. We’ll update you on any developments.
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The newest edition of this Bi-annual report generated from FINCEN is now available. Issue 16 gives a detailed summary of the following:
- Mortgage loan fraud
- Trends and benefits of BSA E-Filing system
- Analysis of SAR inquiries
- Law enforcement cases
- Suggestions for filing a SAR
- What’s new for auditing the AML program
This issue’s Law Enforcement section focuses on SARs filed due to structured transactions. These structures were not completed by the members one may typically scrutinize. Doctors, lawyers and business owners are some of the top professionals performing these transactions. They deal with large amounts of money on a regular basis and they also have the knowledge of the government financial requirements. It is sometimes hard to train our minds to expect impropriety from a respected individual such as a doctor, but that is how our front line staff needs to think. We need to train our staff to flag these accounts as high risk and monitor them accordingly.
Read Issue 16 to learn more about the BSA Advisory Group’s findings.
http://www.fincen.gov/news_room/rp/files/sar_tti_16.pdf
By admin|
Published on Sep 28, 2009
Audit Link, a compliance and audit process division of CU*Answers, has recently announced its community is 25 credit unions strong.
According to the CUSO, the service has far exceeded original expectations of contracting for 20 credit unions in its first two years. Now 25 credit unions strong, it is expected that Audit Link will be providing audit and compliance services to 30 credit union partners within the next 6 months. The CUSO states that it has continually been improving and streamlining its processes, enabling it to address individual credit union needs. It has begun to address larger credit union needs by assisting internal staff in specific areas of auditing including employee review, dormancy monitoring, and file maintenance logs.
According to Jim Vilker, VP of Professional Services for CU*Answers, “Though not unexpected, we have been pleasantly surprised by the reaction of our credit union owners/clients and their willingness to embrace this and other managed services provided by a partnership between CU*Answers and Xtend. We have designed these collaborative ad hoc services to be not only affordable, but to enable credit unions to increase the level of service they provide to their members and gain a competitive advantage.”
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The CU*BASE 5300 Call Report tool was released this summer! Credit Unions now have the ability to enter their Call Report data into CU*BASE. This is a big step toward reducing the burden of completing this quarterly task.
CU*Answers plans to automate the collection of data for the Call Report as much as possible for your credit union. The software has ‘auto-pop routines’ that automatically populate CU*BASE data to your Call Report. Several automation routines are currently available (G/L balances, Security, and Purpose Codes) and we continue to evaluate ideas for future automation routines. Do you have any ideas? Please send them to CallReport@cuanswers.com.
Your credit union has the flexibility to configure exactly which G/L accounts, Security Codes, or Purpose Codes to use for populating NCUA Account Codes depending on Read More »
When What You Think Is Not What You Get
President Ronald Reagan liked to use the term “trust, but verify”. He used the phrase to describe how he dealt with the Soviet Union in reducing the nuclear arms threat.
Recently our Credit Union found out the hard way that what we thought to be true was not true. It began on a Saturday morning with a member calling the office and saying that they had received a suspicious call on their cell phone. The call was a “robo” call in which the member was advised that their debit card had been deactivated and that to reactivate the card they simply needed to press “1″. Upon doing so they were instructed to enter their entire debit card number, their PIN number, their CVV number and the expiration date on the card. Within 45 minutes of the member receiving a phone call, a duplicate card had been created by the criminals and used at an ATM machine Barcelona Spain to withdraw almost $8,000 from the member’s account. Exact quotes of my instant reaction are not printable here. But I can tell you that I immediately said that this couldn’t be since we had specified with our card processor, FIS, that the daily limit at an ATM was $200.00. Read More »
By admin|
Published on Aug 10, 2009
Xtend Inc. a multi-owned cooperative CUSO headquartered in Grand Rapids, Michigan, has seen its Audit Link back office compliance monitoring service grow from eight clients at the beginning of the year to a total of eighteen. The CUSO reports that the service is used by credit unions in seven states and ranging in size from $9 million to $225 million.
Audit Link focuses on the repetitive tasks that need to be done every day for the credit union to stay on top of ever-increasing compliance requirements. Activities include reviews of wire transfer logs, BSA reports, Reg D violations, dormancy activity, OFAC scans, SAR reports, and much more. Says Xtend President Scott Collins, “We expected that this service was going to be widely accepted when we rolled it out, but I must admit we are pleasantly surprised that we have seen such a wide variety of partners put us to work supporting their overall compliance program. That tells me that we are delivering a service that is in demand, and doing so at an effective price point.”
Collins added that he expects the service to continue to as many as thirty clients in the next year. Currently, Audit Link supports credit unions in Michigan, New York, Washington, Oregon, Wisconsin, Indiana, and South Dakota.
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Thanks everyone for participating in the Audit Link Review Course! Please find the slide show below.
Review Course 7-15-09
By admin|
Published on Jun 30, 2009
CU*Answers announces the roll-out of a new service to help clients complete third party due diligence on CU*Answers and partners involved with the cuasterisk.com network.
The “Risk Management Report Generator” is a new Internet-based product which allows CU*Answers, Xtend, Audit Link, WESCO Net, and Lender*VP clients to complete their due diligence on services and products purchased from these CUSO’s. The creation of this product stems from the requirements put forth by the NCUA instructing credit unions to perform due diligence on third party vendor relationships. This tool allows credit unions to keep vital contract information along with legal opinions associated with the correlating contracts. The questions proposed in the Report Generator are modeled directly from the NCUA Supervisory letter and the system will store the assessments. Each year when the assessment is up for review, an e-mail notification will be sent to the CEO.
According to Jim Vilker, cuasterisk.com Network Manager, “Third party due diligence is definitely hitting the radar of regulators and auditors. This is a full vendor management system for credit unions that partner with the cuasterisk.com network. This application allows credit unions to not only complete their due diligence electronically, but to also view how their peers completed the assessment.”Randy Karnes, CEO of CU*Answers stated “We put a stake in the ground at our 2008 Leadership Conference committing to have the lowest cost of compliance in the industry not only for users of our flagship core data processing system, but for all of the services we offer.” This tool is free to use by any credit union purchasing services from the CUSO’s involved in the cuasterisk.com network.
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By admin|
Published on Jun 30, 2009
The new Audit and Compliance division of the cuasterisk network of CUSOs, Audit Link, announced inspiring first year results at CU*Answers Annual Leadership Conference on June 17th.
Jim Vilker, Business Manager of Audit Link revealed that 21 credit unions across the United States, from New York to Oregon have come on board to use Audit Links services. More than 420 recommendations have been made to help credit unions improve their compliance and auditing related activities, policies, procedures, and disclosures. Vilker also stated that the daily work performed by Audit Links compliance specialists and other collaborative initiatives have led to over 25 changes in the CU*BASE platform that will ultimately assist credit unions in lowering their overall cost and increase efficiencies relating to audit-related operations.
Audit Link is a growing community of credit unions wishing to collaborate and gain a firm grasp on compliance and auditing related activities in their credit unions. The community is becoming one where credit unions can share their experiences and expertise through the use of a similar technology network and infrastructure. The recently released Audit Link Advisor web site has also given CU*BASE clients the ability to blog between each other and have a one-stop site to gain pertinent industry-related compliance and auditing news. – Jim Vilker
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Once you understand the basic principle behind the Red Flags Rule, creating a written Indentity Theft Program becomes easier to achieve. Notice the operative word is ‘easier’, not easy. We’ve discovered a website that offers valuable insight into designing an Identity Theft Compliance program of your own. Based on a template developed by the FTC, the federal agency that enforces a number of consumer protection laws, you will build your program using a four step process. Here’s help with your efforts to implement an Identity Theft Prevention Program in your organization.
This website, http://www.ftc.gov/redflagsrule is based on Fighting Fraud through optimizing your ability to detect suspected cases of Identity Theft before they occur. Using an online interview approach, you will complete answers to questions that force your thinking into a pattern of detecting and mitigating areas where your credit union may be vulnerable to identity risks.
