CUNA’S BSA 101 2024 COMPREHENSIVE QUESTIONS
AND VERIFIED ANSWERS APPROVED STUDY GUIDE
(100% CORRECT) LATEST EDITION
What is the primary purpose of including joint owners' information on a CTR?
a) To facilitate the transfer of funds between joint account holders.
b) To ensure transparency in financial transactions and prevent illegal activities such as
money laundering.
c) To determine the total amount of funds in the joint account.
d) To provide information for tax reporting purposes.
b) To ensure transparency in financial transactions and prevent illegal activities such as money
laundering.
In the scenario where John withdraws $7,000 cash from a joint account without Sarah
present, should Sarah's information be included on the CTR?
a) Yes, because she is a joint owner.
b) No, unless there are facts suggesting she will benefit from the transaction.
c) Yes, regardless of her involvement in the transaction.
d) No, because she is not making the withdrawal.
b) No, unless there are facts suggesting she will benefit from the transaction.
How long are financial institutions required to retain copies of CTRs?
a) 2 years
b) 3 years
c) 5 years
d) 10 years
c) 5 years
Why Congress enacted the Bank Secrecy Act (BSA)?
To assist law enforcement in the investigation and obstruction of money laundering, terrorist
financing, tax evasion and other criminal activity
Which year Congress enacted the Bank Secrecy Act (BSA)?
1970
The "BSA Act" is made up of how many statutes?
There are 8 statues:
1. Currency and Foreign Transaction Reporting Act of 1970.
2. the Money Laundering Control Act of 1986
3. the Anti-Drug Abuse Act of 1988
4. the Anti-Money Laundering Act of 1992
5. the Money Laundering Suppression Act of 1994
6. the USA Patriot Act of 2001
7. the Anti-Money Laundering Act 2020.
8. the Corporate Transparency Act of 2020
,How often FinCEN requires regulators to submit statistics?
Federal regulators are required to compile BSA compliance statistics on the institutions they
regulate and provide these statistics (quarterly) to FinCEN.
What is duty of BSA Compliance officer? and what does NCUA requires?
NCUA lists "BSA Compliance" as a supervisory priority each year and requires field examiners
to apply "rigorous scrutiny" during BSA/AML related examinations.
What are the minimum requirements for BSA/AML regulation require BSA Compliance
Programs to include?
1. A qualified BSA compliance officer;
2. A system of internal controls;
3. Independent testing.
4. Training for all appropriate personnel.
5. Ongoing member due diligence.
What are credit unions' compliance programs must be?
• in writing,
• approved by the credit union's board of directors,
• reflected in the minutes of the board meeting.
List requirements for BSA/AML program
1. A Qualified BSA Compliance Officer
2. A System of Internal Controls
3. Independent Testing
4. Training for all Appropriate Personnel
5. Ongoing Member Due Diligence
6. Customer Identification Program:
What are responsibilities of BSA compliance officer?
* Responsible for coordinating and monitoring day-to-day BSA/AML compliance
* Must be appointed by the board of directors
* Expected to be fully knowledgeable of the Bank Secrecy Act and all related regulations,
* Understand the money laundering and terrorist financing risks associated with each of the
credit union's products, services, members, and geographic locations.
System of Internal Controls
Refers to the policies and procedures the credit union puts in place to limit and control risks
associated with BSA/AML.
Independent Testing
An audit of the BSA/AML compliance program be conducted by the internal audit department,
outside auditors, consultants, or other qualified independent parties.
For example, the BSA Officer cannot test any part of the BSA/AML Compliance Program.
Training for all Appropriate Personnel
the credit union's BSA/AML training program must provide training for all personnel whose
duties require knowledge of the BSA.
The training should be tailored to the person's specific responsibilities.
While the board of directors (BOD) may not require the same degree of training as the credit
union's operations personnel, the BOD must understand the importance of BSA regulatory
requirements, the ramifications of noncompliance, and the risks posed to the credit union.
,Ongoing Member Due Diligence
Requires credit unions to have appropriate risk-based procedures for conducting ongoing
member due diligence.
To meet this requirement the credit union must develop a member risk profile, which means
understanding the nature and purpose of each member relationship, as well as expected
transaction activity, in order to provide a baseline against which your member's activity is
assessed for suspicious activity reporting, such as the type of member or type of account, service,
or product, as well as ongoing monitoring to identify changes.
Ongoing due diligence monitoring applies to ALL of your members to help you better determine
whether a member is or isn't "higher risk".
The level of risk for each individual account must be determined by performing a risk
assessment unique to each account.
If the credit union determines that a member or account presents a higher risk, the credit union
must perform enhanced due diligence for this account.
Customer Identification Program:
The credit union's BSA/AML Compliance Program must also include a Customer (Member)
Identification Program (CIP or MIP) to effectively identify and verify the identity of every
member and customer opening an account
What is the Federal requirements for BSA Risk Assessment?
The federal regulators recommend reassessing the BSA risk at least every 12 to 18 months.
Risk assessment link to the BSA/AML compliance program
The credit union's BSA Officer is ultimately responsible for the credit union's BSA
compliance.
True
False
False
The BSA Officer must be knowledgeable of:
a. The 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.
f. All of the above.
, If you are a small credit union (less than $100 million) it is acceptable to have the BSA
Officer identify when BSA-related reports must be filed, fill out the reports, and determine
when members are eligible to be exempt from BSA reporting.
True
False
False
Regulators recommend that independent testing of your BSA program should be done:
What does CIP or MIP stand for?
Customer Identification Program
or
Member Identification Program
A credit union's CIP/MIP must be risk-based and should be tailored to:
• its size,
• location,
• types of accounts offered,
• methods of opening accounts,
• any other risk factors the credit union believes will affect its CIP/MIP procedures.
The regulation requires credit unions to get at least four pieces of information for each new
member and customer:
• Name,
• Date of birth,
• Address,
• Identification number.
Verification
Verification of identity must be done before or within a reasonable time after the account is
opened.
you must verify enough information to form a reasonable belief that you know the true identity
of the member,
How many methods can CU use to verify identity of a member?
There are two methods that credit unions can use to verify identity:
1. documentary
2. nondocumentary methods.
Documentary Method
requires the use of an unexpired government-issued identification card, such as a driver's license,
passport, or military ID.
nondocumentary methods.
methods generally will include such items as:
(a) comparing the information provided by the person with information obtained from a credit
bureau, or against fraud and bad check databases,
(b) obtaining references from other financial institutions,
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