Gen Ops

Question 1

The two major requirements of the Bank Secrecy Act are….

Answer 1

Reporting requirements and record keeping requirements

Question 2

When a member conducts a currency transaction that exceeds 10k the credit union has no duty to notify the member that it must file a CTR

Answer 2

True

Question 3

CTRs must be e filed within how many days?

Answer 3

15

Question 4

When a credit union looks at a members gov issued picture ID to verify identity, has it satisfied MIP requirement that credit union has a reasonable belief that it knows the true identity of the person?

Answer 4

Yes

Question 5

What does a company have to do to receive a “payroll customer” exemption from CTR reporting requirements?

Answer 5

Company must have maintained a transaction account at the cu for at least two months, regularly withdraw over 10k in currency to pay employees, and be incorporated under US or state law

Question 6

Can the “payroll customer” exemption be used for deposits?

Answer 6

No

Question 7

What is the “special order geographic reporting requirement” of the BSA (section 5326)?

Answer 7

Nothing more than an order from the Treasury requiring filing of CTRs at a specific geographic location for transactions 10k or less

Question 8

Who will the notice of the special order for geographic requirement be directed to?

Answer 8

Credit Union CEO

Question 9

For geographic special order, will the notice outline the types of transactions that are subject to the order?

Answer 9

Yes

Question 10

SARs must be filed for robberies and/or burglaries?

Answer 10

No

Question 11

If a member pays for a cashier’s check or money order in amounts from 3k to 10k, the credit union must keep a record of what?

Answer 11

Member’s name, date of sale, amount, serial number, and type of instrument

Question 12

Must credit union keep a log of transactions to purchase monetary instrument 3k to 10k made with cash?

Answer 12

No

Question 13

What three things must a credit union BSA compliance program do?

Answer 13

Be in writing and be approved by board of directors, have ongoing training on the BSA for the credit union’s employees, and have independent testing for the credit unions compliance with the BSA’s requirements

Question 14

True or false: the NCUA and regulations section 748.2 dealing with the BSA requirements for federal credit unions requires the credit union to file an annual report with the NCUA

Answer 14

False

Question 15

Does the right to financial privacy act apply to all members of the credit union?

Answer 15

No

Question 16

Does the right to financial privacy act apply to state and local government authorities?

Answer 16

No, only federal government authorities

Question 17

What are the two main requirements of the Right to Financial Privacy Act?

Answer 17

General prohibition against disclosure and record keeping requirements

Question 18

If a member grants a federal agency permission to examine her financial records, the permission form they sign must include a provision for financial compensation for any inconvenience to the member

Answer 18

False

Question 19

If a member authorized the release of records to a federal agency in writing, the statement must specify the purpose for the release of information, the name of the agency to receive the info, and that the member has the right to receive a copy of the records that are released. Also the member can revoke the authorization

Answer 19

True

Question 20

Are CTRs, SARs, 1099s, and bankruptcy claims exempt from RTFPA?

Answer 20

Yes

Question 21

If federal agents demand a members info under an exception to the RTFPA, the cu should make sure the release comes under an exception (typically by contacting an attorney) before releasing the information

Answer 21

True

Question 22

If cu receives an administrative subpoena or a judicial subpoena, the cu should not release any records until it receives a certificate of compliance

Answer 22

True

Question 23

If feds present cu with a search warrant, the cu should release only the info described in the warrant

Answer 23

True

Question 24

Under RTFPA records must be retained forever

Answer 24

True

Question 25

When you sign an account card/form (substitute w9), you are certifying to the IRS that your name and SSN match, that you’re not subject to withholding, and that you are a us person

Answer 25

True

Question 26

IRS considers mistakes what as errors on information returns (subject to penalty)?

Answer 26

Mistakes in SSN, address, last name, and dollar amount

Question 27

A credit union that is required to apply withholding must notify member within 15 days after withholding begins

Answer 27

True

Question 28

NCUA privacy regs define a member as an individual with a continuing relationship at the credit union

Answer 28

True

Question 29

If a cu does not anticipate disclosing info to affiliates or non-affiliated third parties for marketing purposes, the cu is completely exempt from NCUA privacy regs

Answer 29

False

Question 30

Verbal privacy notices are okay if member signs a statement acknowledging the receipt of the verbal notice

Answer 30

False

Question 31

The cu does not anticipate disclosing info to affiliates or non-affiliated third parties for marketing purposes, the cu can provide a shortened, simplified notice

Answer 31

True

Question 32

There are significant penalties and civil liabilities for CU for violating the NCUA privacy regs

Answer 32

False

Question 33

Is staff training on the security program required per NCUA requirement for the credit unions member information security program?

Answer 33

Yes

Question 34

What three things does NCUA guidance concerning electronic authentication program include?

Answer 34

Developing a process that is consistent and supports the credit unions overall security and risk assessment program, that is periodically reviewed, and that includes auditing and monitoring features

Question 35

Under it’s data security response program, a credit union may contract with its service provider to notify all of its members and regulators that its information system has been breached

Answer 35

True

Question 36

COPPA (children’s online protection program act) is a federal law enacted to prohibit unfair or deceptive Internet acts or practices in connection with the collection, use, and/or disclosure of personal information from and about children under the age of 13 who can access websites via the Internet

Answer 36

True

Question 37

COPPA applies to a cu whose website can be merely accessed by children under 13

Answer 37

False

Question 38

If cu plans to collect, use, and disclose personal info from children under 13, COPPA requires cu to have a website notice, a parental notice, and obtain parental consent

Answer 38

True

Question 39

Prior to a member conducting business electronically, e-sign mandates that member be given an error resolution notice and procedures

Answer 39

False

Question 40

Per e-sign how long is members affirmative consent good for?

Answer 40

Forever

Question 41

CU must submit a request form detailing compliance with e-sign and NCUA or FRB before it can accept and rely on esignatures or engage in transactions sanctioned by the act

Answer 41

False

Question 42

If cu files an ofac report it must retain report indefinitely

Answer 42

False (5 years)

Question 43

If cu violates ofac it can lose NCUA insurance coverage

Answer 43

False

Question 44

Ofac requires cus that have filed reports to conduct annual audits and file annual reports of blocked property

Answer 44

True