· A description of why you have suffered a loss (for example, you think the amount withdrawn was incorrect);
· An estimate of the amount of your loss;
· An explanation of why the substitute check you received is insufficient to confirm that you suffered a loss; and
· A copy of the substitute check (and/or) the following information to help us identify the substitute check: (identifying information, for example the check number, the name of the person to whom you wrote the check, the amount of the check).




WALLINGFORD MUNICIPAL FEDERAL CREDIT UNION
SHARE DRAFT POLICY
EFFECTIVE 7/1/2002

QUALIFICATIONS FOR ELIGIBILITY
A. All members in good standing with an active share account.
B. A Minimum deposit of $5.00 to open a share draft account.
C. A $5.00 minimum balance required to maintain a share draft account.
D. Must not have a delinquent credit history.
E. Must be eighteen (18) years old.

DIVIDENDS ON SHARE DRAFT BALANCE
A. Share Drafts do not receive dividends.

ENROLLMENT
A. Must fill out appropriate application forms.
B. For a joint share draft account, both applicants must be members.

DEPOSITS TO SHARE DRAFT ACCOUNTS
A. May be made in person at Credit Union office.
B. By payroll deduction.
C. By mail, using deposit slips available with share drafts.
D. Transfers from a share account.

COST OF DRAFTS AND MONTHLY FEES
A. Actual cost of drafts will be deducted from your share account.
B. NO monthly fees.

DUPLICATE CHECK METHOD
A. Original share draft is never returned.
B. Duplicate share draft and monthly statement provides proof of payment.
C. Copy of share draft will be supplied for a nominal fee;
1. Original draft is kept on file for 60 days.
2. Microfilm copy is kept for seven (7) years.

STATEMENT
A. Mailed monthly.
B. Reconciliation assistance by appointment only.

CLOSING ACCOUNTS
A. The Credit Union reserves the right to close a share draft account for any of the following reasons;
1. An inactive account with a less than $5.00 balance for 30 days.
2. Three (3) overdrafts in a month, or six (6) in a year.
3. Member becomes more than two (2) months delinquent on a WMFCU loan.

APPROVED BY THE BOARD OF DIRECTORS AT THEIR MEETING OF MAY 15, 2002

WALLINGFORD MUNICIPAL FEDERAL CREDIT UNION
CHECK CASHING POLICY
EFFECTIVE JUNE 13, 2002

The Board of Directors of the Wallingford Municipal Federal Credit Union offers a check cashing service to the members of this Credit Union. The goal of this service is to offer a convenient means of cashing members checks when funds are available in the Credit Union Business Office. The following rules shall apply when offering this service.

· All Town of Wallingford checks paid to a member of this Credit Union, up to $5000.00 will be cashed.

· Any member cashing a payroll check not issued by the Town of Wallingford or a personal check not drawn on this Credit Union must have sufficient funds available in their share account to cover the amount of the check. If the funds are available the check will be cashed and a (10) ten-day hold will be placed on the funds in their share account. If the funds are not available the check will not be cashed. The only exceptions to this will be checks drawn by the State of Connecticut, U.S. Government, other Connecticut Municipalities, large corporations and Utility companies.

· All non-members cashing a members Credit Union check drawn on their share account or a Credit Union members personal check, drawn on the members share account, shall be required by the Credit Union staff to do the following:
1. Present a Valid Drivers License, which shall be photocopied.
2. Removal of their hat and/or sunglasses for photo identification.
3. Look into the video camera for security reasons.
4. There will also be a (5) five-day hold placed on the funds in the member’s account.
The above procedure shall be followed or the check will not be cashed.

· Only the Board of Directors or the Manager/CEO of the Credit Union is authorized to make exceptions to these policies.


APPROVED BY THE BOARD OF DIRECTORS AT THE MEETING OF June 13, 2002

WALLINGFORD MUNICIPAL FEDERAL CREDIT UNION
LENDING POLICIES
EFFECTIVE FEBRUARY 13, 2003

ELIGIBILITY:
A loan applicant must be a member of this Credit Union with one full share on deposit to be eligible for a loan.

APPLICATION:
The applicant shall complete all applications in full before they can be presented for approval.

ACTION:
The Credit Union will, within seven days of the applications review, notify the applicant of the approval or denial of the loan application by the Credit Committee.

NON-DISCRIMINATION:
The Credit Union will not discriminate against any loan applicant on the basis of race, color, religion, national origin, gender, age, marital status or because all or part of an applicant’s income is derived from any public assistance program or because the applicant has, in good faith, exercised his/her right under the Consumer Protection Act.

BASIS FOR LOAN GRANTING:
1. That all loans are made for a meaningful (provident and productive) purpose.
2. That the applicant in question has the ability to repay the loan, within the terms of the note.
3. That collateral will be as regulated by the directors, the bylaws and    statutes which govern this aspect of Credit Union service.
4. That all types of loans shall require a Credit Bureau report prior to consideration.
5. That a derogatory comment or bad credit rating on a credit report is satisfactorily explained in writing.
6. That an inquiry of the Register of Deeds records may be made for all loans where the collateral is other than a titled motor vehicle.
7. That debt consolidation loans will be paid directly to creditors.
8. That the applicant is responsible for up to $200.00 in rent even if the applicant does not pay rent.
9. That income to expense ratio of a loan shall be a factor in determining if a loan should be approved.  The INCOME TO EXPENSE RATIO for collateral loans for this Credit Union is 55% and for personal loans the ratio for this Credit Union is 50%.   Any loan approved, which exceeds that ratio, shall be reported to the Board of Directors at the next regularly scheduled Board meeting.

EXCHANGE OF CREDIT INFORMATION:
The exchange of credit information among credit grantors is normal trade practice.  Credit about member accounts may be provided to a Credit Bureau and its affiliates; the exchange of credit information with other credit grantors in not a violation of or the responsibility of the Directors, Credit Committee and employees of the Credit Union.  The provisions of the Fair Credit Reporting Act and regulations shall apply.

REWRITE OF LOANS:
No rewrite of a loan shall be considered until three (3) monthly payments are received against the loan being rewritten.

LOAN OFFICERS: *
The Board of Directors, in cooperation with the Credit Committee, is authorizing the Loan Officers of this Credit Union, to grant loans to members providing that such loans are based on the provisions as delineated in these policies.

The Loan Officers are also designated, by the Board of Directors, to act as alternate Credit Committee members in the absence of a quorum of regularly elected committee members.  The loan officers shall be the Board Treasurer, Management and Office Staff of the Credit Union.

In an emergency situation where the health and wellbeing of the member, or their family is involved a loan officer can sign off on a loan.  Any loan approved in this situation will be reported to the Board of Directors at their next regular meeting.

During loan specials when an immediate turn around on loans is part of the promotion, a loan officer may sign off on a loan.  Any loan approved in this situation will be reported to the Board of Directors at their next regular meeting.

LATE FEES:
Loan payments that are ten days past due will be charged a late fee, this fee will be delineated in the fee schedule.  This applies to all loans approved after 1/16/2003.

RATES OF INTEREST:
In conformance with the Credit Disclosure Act (Truth in Lending), the Wallingford Municipal Federal Credit Union shall calculate interest on the unpaid balance for all loans on the number of days the principal was used, incorporating the Julian calendar, as approved for Credit Unions using data processing services.

 Example: P x R x T = I  $1,000 x 12% x 31/365 = $10.19

LOAN LIMITS:
Established by a majority vote of the Board of Directors.

MAXIMUM LIMITS:
The limits offered by the Credit Union are absolute maximums and are not intended to indicate the amount of credit or length of time that credit will be extended to every member.  Each application is reviewed according to the consistent criteria used by the Credit Committee to determine each individual’s ability to incur and repay the requested amount.

The maximum limits on all Regular, Co-Signer and Automobile loans may be exceeded by using shares within a member’s account.  The release of the shares as collateral will take place when the outstanding loan balance is below the maximum loan limits establish by the Board of Directors.
 

PAYROLL DEDUCTIONS:
For members electing to make loan payments by payroll deductions:  In accordance with the procedures in effect between the payroll department and the Credit Union, members may request that a certain amount be withheld from their pay and sent to the Credit Union.  The Credit Union deposits these funds to the member’s share account upon receipt.  On the contractual date of the loan payment the money is transferred to the loan from the share account.  It is entirely the member’s choice to arrange payment in this fashion.  Any money the Credit Union receives belongs to the member until it is posted to the loan.  If there are not enough funds in the account on the transfer date, the loan will be delinquent and subject to late charges.  The simplicity and economy of payroll deductions help the Credit Union provide better service.  It is the member’s responsibility to see that there are sufficient funds in the share account to meet the loan payment.  Upon payroll deduction agreement with the Credit Union the member will the sign an agreement stating that they accept the payroll deduction and take full responsibility of any withdrawals they make that short their loan.  This will be kept in their loan folder and they will be given a copy for their records.   The Credit Union is not responsible for delays in processing a deduction request made by the member to the payroll department.

AGGREGATE LOAN LIMIT:
Exclusive of share secured loans, the maximum secured loans of any member is $80,000.  The maximum unsecured loans, including any special promotions or personal loans is $12,000.

The Credit Union shall limit the total amount loaned for second mortgages to its members to 20% of the total loan portfolio.

LOANS TO STAFF, MEMBERS OF BOARD AND COMMITTEES:
Wallingford Municipal Federal Credit Union staff, management, officers, board and committee members are in positions of trust and are expected to adhere to high standards.  Their loans are to receive the special attention and recommendation of the president and the credit committee/loan officer to assure that high standards always apply and that there is no question of collectibility.

All loans to the staff of this Credit Union shall only be reviewed for approval or denial by the credit committee.  Loan processing for employee loans, however, will not differ from other loans.  This same ruling shall apply to next of kin of such employees.  No loan shall be made to any employee without obtaining assurance of collateral value, which, in the opinion of the credit committee, will assure collectibility of such a loan.

The above conditions shall also apply to all directors and committee members of the Credit Union.

Loans to members of the Credit Committee and Loan Officers shall be approved by a quorum of the Board of Directors.

The Board of Directors shall review for approval or denial all Loans in the aggregate of $20,000 to staff, board members and committee members.  When a loan is brought before the board under this section the applicant shall be absent from the discussion.
 

MEMBERS LEAVING THE FIELD OF MEMBERSHIP OR LIVING OUT OF STATE
Members leaving the field of membership and moving out of state but still retaining their accounts are encouraged to take out loans with the Credit Union.  The member is encouraged to be present at the Credit Union office to sign the loan note.  The member may choose to have the paperwork sent to them for execution.  Paperwork sent to a member for execution must be returned to the Credit Union fully executed and properly witnessed by a Notary Public or Clerk of the Court.  The Credit Union will issue the loan after all paperwork is returned and properly executed.

LOANS TO MEMBERS LEAVING THE UNITED STATES:
Loans to members leaving the United States or members who will be out of the continental United States during the period of the loan payment shall provide a co-maker as security.

LOAN COMMITMENTS:
The quotations of personal loan rates are for information purposes only and are subject to change.  A signed loan application will commit a rate for up to 39 days.

LOAN PROTECTION INSURANCE:
Loan protection insurance will be provided to an aggregate limit of $20,000 per member, by the Credit Union, for all members meeting the eligibility requirements of the group policy.

Member disability insurance is also offered to all members.  This is a member paid insurance that upon request of the insurance it will be incorporated into the loan payment

Members shall be encouraged to take group mortgage insurance protection and shall be required to take Flood, Fire & Hazard Insurance on all Second Mortgage Loans with the Credit Union listed as loss payee.  The loan limits will be a maximum of $75,000 and a minimum of $10,000, with a maximum term of twelve years.

Members requesting an automobile loan shall have their agent or insurance company submit a loss payable endorsement listing the Wallingford Municipal Federal Credit Union as loss payee of lien holder.

PRIOR LOSS:
No person who has caused a financial loss to the Credit Union shall be approved for any type of credit and shall not be approved as a co-maker on any type of loan.

APPEALS OF DISAPPROVED LOANS:
Members who have their application refused by the Credit Committee may request a personal interview to discuss the application.  The member must request the interview in writing, outlining the additional information he/she wishes to present to the committee.

The Credit Committee will evaluate the letter to determine if a meeting with the member would be advantageous to the member.

APPROVED BY THE BOARD OF DIRECTORS AT THEIR MEETING OF FEBRUARY 13, 2003

Wallingford Minicipal Federal Credit Union
Risk Bases Lending Policies
Effective November 14th,2003 

Risk Based Lending (RBL) is a system of assigning risk values to applications based on the potential for default or loss, thereby allowing the lender to price loans accordingly.  The purpose in offering risk-based loans is to help as many loan applicants as possible.  The Credit Union recognizes that certain members represent more risk than others.  The Credit Union will not grant any loan where the probability of repayment is very doubtful.  The credit Union also realizes the importance of managed risk.  The Credit Union believes we have members who are being charged extremely high rates with other lending institutions and that the Credit Union could help with a managed risk program while helping the member rebuild their credit.

The Credit Union understands there are basically three types of risk when it comes to granting loans:
· Liquidity Risk
· Interest Rate Risk
· Default Risk

LIQUIDITY RISK:
The Credit Union simply runs out of available funds to loan to our members.  The Board of Directors relies on Management to have a good asset liability management program.

INTEREST RATE RISK:
The Credit Union will protect itself against interest rate risk by:
· Having an adequate percentage of re-priceable loan products in our loan portfolio.
· Using a tiered system for interest rates on signature loans.
· Using a tiered system for interest rates on collateral loans for a variety of years.  The longer the maturity, the higher the rate.

By using a tiered approach and multiple pricing by product, we can maintain our margins as rates go up or down.

DEFAULT RISK:
The Credit Union will always use judgment in granting loans.  The scoring models will only tell us what rate to charge if we elect to approve the loan.  The scoring model will be a tool that will assist, the Credit Committee and the Loan Officers, in the decision process.  The credit bureau we employ uses the Empirica scoring system.  It is the policy and practice of the Credit Union not to discriminate, which is the reason we have selected the Empirica scoring system.  Fair Isaacs, a leader in developing scoring systems, developed this scoring system.  Fair Isaacs tested thousands of files, uses over 50 characteristics in determining the members’ score and have been found to be non-discriminatory.

1. When determining the rate to charge, if two or more scores are offered, the Credit Union will adhere to the following:
· In the event the two signers are joint borrowers, the credit score will be based on the higher of the two scores.
· In the event there is a maker and a co-maker, the credit score will be based on the makers score only.
2. In the event there is no credit report to score, the Credit Union will assign a Tier 2 score for all applicants.
3. If two credit bureau reports are obtained, resulting in two different scores, the credit score will be based on the higher of the two scores.
 
LOAN RATES: 
The Wallingford Municipal Federal Credit Union will use the following scoring ranges based on the Empirica model profile used by our credit bureau to determine the applicable interest rate:
  Tier 1 - 675 & Over Base Rate
  Tier 2 - 625 to 674 +1%
  Tier 3 - 575 to 624 +2%
  Tier 4 - 525 to 574 +3%
  Tier 5 - Below 525 +4% & requires Credit Committee Approval

Lending rates distributed and posted by the Credit Union reflect the Tier 1 rate offered by the Credit Union.

APPROVED BY THE BOARD OF DIRECTORS AT THEIR MEETING OF NOVEMBER 13, 2003

Wallingford Municipal Federal Credit Union
Savings Bond Policy
Effective July 11,2002

The Wallingford Municipal Federal Credit Union (WMFCU) is an issuing agent for US Savings bonds Series EE and I. WMFCU and its members applying for bonds are subject to all rules and regulations established by law, as may be amended from time to time, for this savings plan.

· Bonds will be sold to WMFCU members only
· Savings Bonds can be purchased “over the counter” or through a “payroll deduction plan”

“Over the counter” sales
· Member must fill out the applicable bond form and submit the order form to WMFCU.
· The purchase price of the bond may be paid either with cash or transferred from a member’s account.

“Payroll Deduction Plan”
· Member must open a separate federal suffix f account under their existing share account number.
· This is not an interest bearing account.
· A deposit of $5.00 required upon opening this account.
· A balance of $5.00 must be maintained.
· The member must complete the applicable form and submit it to WMFCU. This form will be kept on file for the regular purchase of Savings Bonds.
· All “F” accounts will be reviewed on a weekly basis


Series EE

· Sold at half their face value (You pay $25 for a $50 bond)
· Buy as much as $15,000 per year
· Earn 90% of market rates on five-year Treasury securities


Series I

· Sold at face value (You pay $50 for a $50 bond)
· Buy as much as $30,000 per year
· Offer a real rate of return over and above inflation


For more information on US Savings Bonds visit www.savingsbonds.gov


Approved by the Board of Directors, at their meeting, July 11, 2002




APPROVED BY THE BOARD OF DIRECTORS AT THEIR MEETING OF JUNE 13, 2002

WALLINGFORD MUNICIPAL FEDERAL CREDIT UNION OFFICE OF FOREIGN ASSETS CONTROL (OFAC) POLICY

The Board of Directors of Wallingford Municipal Federal Credit Union has adopted this policy and is implementing procedures to assure and monitor compliance with the requirements of the Office of Foreign Assets Control (OFAC).

General Policy Statement
The Office of Foreign Assets Control (OFAC), Department of the Treasury, is responsible for administering a series of laws that impose sanctions against select foreign countries and persons to further U.S. foreign policy and national security objectives. Any transactions, such as transfers of funds, to or from these countries or to blocked persons are prohibited. The credit union is required to block such transfers and accounts and furnish reports on all blocked accounts and rejected funds transfers to the OFAC. This policy is adopted in order to ensure compliance with applicable OFAC requirements.

The Board of Directors of the Wallingford Municipal Federal Credit Union supports the implementation and operation of the OFAC program in an effort to ensure compliance with the following related federal laws:

• Performing ongoing research for any regulatory changes
• The Compliance Officer or other designated individual will periodically visit the OFAC web site to keep current with new regulations and listings.
• Recommending changes to the OFAC policy when necessary
• Assisting the development of an effective training program and monitoring its progress for quality and effectiveness

• Providing staff sufficient information to enable them to recognize and stop suspect transactions
• Reviewing any transactions stopped by staff under this policy for compliance
• For staff training and implementation of all the requirements of this policy.

1. New Accounts. Each time a new member opens a new account relationship, the credit union will check that person's name with the current OFAC list. The credit union will use appropriate means to conduct the screening, including employing an outside service bureau like Chex Systems to verify the data, using a filter from a third-party provider, or by checking the current list manually orby searching the most current file electronically.
   
2. Western Union Money orders, travelers checks, official checks, third-party checks.
   
3. Specially Designated Nationals and Blocked Persons. The primary tool used by the OFAC is a listing of "Specially Designated Nationals and Blocked Persons." This list changes regularly in response to changes in foreign policy. The Credit Union staff shall be aware of the persons and entities on the list and assure that such accounts and transactions are blocked and reported to the OFAC in compliance with OFAC regulations.
   
4. Compare Existing Account Portfolio Against OFAC List. The credit union will periodically verify its existing account portfolio against the OFAC list.
   
5. Incoming and Outgoing Wire Transfers (Domestic and International). Since these are real-time transactions, the credit union cannot depend on a service provider who might not complete the review until the next business day.
   
6. ACH Transfers. As an Originating Depository Financial Institution (ODFI) the credit union must verify that the originator is not a blocked person. The credit union must make a good faith effort to determine that the originator, in the normal course of business, is not engaged in transmitting funds to, from, or on behalf of parties subject to sanctions. The credit union, as an ODFI, may rely on the Receiving Depository Financial Institution (RDFI) for compliance when the RDFI holds the account or is otherwise acting on behalf of a blocked person. As a general rule, the credit union is not required to unbatch batched transactions to screen the receiving party. As an RDFI, the credit union must screen receiving account holders for blocked party status.
   
7. Handling Transactions to be Blocked or Rejected. When a match occurs the credit union will take the following action: (1) If the transaction is a deposit, the credit union should accept the funds and immediately place the funds in a blocked account so that no funds can be withdrawn, unless the transaction is one that should be rejected (see below), in which case the credit union should refuse to proceed with the transaction. (2) If the transaction is a transfer of funds (by, through or to the credit union), the credit union should accept the funds, but instead of transferring them, put them in a blocked account. Again, if the transfer of funds is one that should be rejected, the credit union should refuse to proceed.

1. Furnish on Demand. Upon the request of the Director of the OFAC, the Credit Union will furnish in the form of reports or otherwise, complete information relative to any transaction, subject to the OFAC regulations or relative to any property in which any foreign country has any interest of any nature whatsoever, direct or indirect.
2. Blocked Property. If the Credit Union holds blocked property or funds transferred, it will keep a full and accurate record of the property, and the record shall be available for examination for at least five years after the date the property is unblocked.
   • Initial Report. An initial report is required to be filed within ten business days from the date that the payment or transfer received by the Credit Union or the property in the account becomes blocked. The initial report will describe the owner, the property, its location, any account number, the value and the date it was blocked, and the name and address of the holder, along with the name and telephone number of a contact person from whom compliance information can be obtained. If the report involves the receipt of a blocked payment or transfer of funds, the report also will include a photocopy of the payment or transfer instructions received and will confirm that the payment has been deposited into a new or existing blocked account which is labeled as such and is established in the name of, or contains a means of clearly identifying the interest of, the individual or entity subject to blocking pursuant to the OFAC requirements.
   • Annual Report. A comprehensive report on all blocked property held by the Credit Union as of June 30 of the current year will be filed annually with the OFAC by September 30. The annual report will be filed using Form TDF 90-22.50, Annual Report of Blocked Property or an approved alternative form. A copy of the annual report will be retained by the Credit Union. All reports must be filed with the Office of Foreign Assets Control, Compliance Programs Division, U.S. Treasury Department, 1500 Pennsylvania Avenue NW.--Annex, Washington, DC 20220.
3. Rejected Funds Transfers. The Credit Union will report any circumstances where it rejects a fund transfer where processing the transfer would violate, or facilitate an underlying transaction that is prohibited under OFAC. Examples of transactions involving rejected funds transfers include funds transfer instructions:
   • Referencing a blocked vessel but where none of the parties or financial institutions involved in the transaction is a blocked person;
   • Sending funds to a person in Iraq;
   • Transferring unlicensed gifts or charitable donations from the Government of Syria or Sudan to a U.S. person;
   • Crediting Iranian accounts on the books of a U.S. financial institution;
   • Making unauthorized transfers from U.S. persons to Iran or the Government of Iran; and
   • Any commercial activity in Libya, Iraq, or Sudan, not involving a Libyan, Iraqi or Sudanese governmental entity.
   The Credit Union will file a report within ten business days after rejecting instructions to execute payments or transfers involving underlying transactions prohibited by the OFAC regulations. The report will include the name and address of the transferee financial institution, the date of the transfer, the amount of the payment transfer, and a photocopy of the payment or transfer instructions received, and shall state the basis for the rejection of the transfer instructions. The report shall also provide the name and telephone number of a contact person at the transferee financial institution from whom compliance information may be obtained. The report will be filed with the Office of Foreign Assets Control, Compliance Programs Division, U.S. Treasury Department, 1500 Pennsylvania Avenue NW,-Annex, Washington, DC 20220.
4. Record Keeping. The Credit Union will keep a full and accurate record of each blocked account, blocked payment, or transfer. The Credit Union will maintain these records for at least five years after the date of the transaction. These records must be available for examination by the OFAC. If the Credit Union holds property blocked or funds transfers retained pursuant to the OFAC regulations, it will keep a full and accurate record of the property, and the record shall be available for examination for the period of time that such property is blocked and for at least five years after the date such property is unblocked.

Definitions. The definitions noted in the OFAC compliance requirement are to be included as part of the ongoing in-house training program of all staff. The following are specific OFAC-compliance related words that require special attention:
• Blocking. Blocking, also referred to as "freezing," is a process to control assets under U.S. jurisdiction. While the property remains with the designated country or national and in their name/title, the right of the powers and privileges associated with ownership, i.e., moving funds, with authorization from OFAC, is prohibited.
• Blocked Accounts. Type of account where payments, transfers, withdrawals, or other transactions may not occur without approval by OFAC. Debits are prohibited; however, credits are authorized.
• Offset. Exercise of right to net out mutual indebtedness. Offset prohibits transfer of frozen assets in situations of blocked property.
• Specially Designated National Person(s) often are not nationals of a "target country" but are treated as nationals by the U.S. Government in applying sanctions to their transactions. Often referred to as "front organizations". Additionally, the term occasionally includes actual nationals identified as being of special concern to the U.S. Treasury Department.

• Provide internal controls for ongoing compliance
• Provide for independent testing and compliance
• Designate an individual who will be responsible for day-to-day monitoring of transactions affected by BSA requirements
• Provide staff training to educate all personnel who may come in contact with or handle large currency transactions as to their responsibilities under the BSA on an annual basis

• Review all completed forms for accuracy and disposition
• Confirming the retention of these records for the five years required by the BSA
• Confirming that filing of regulatory forms is completed within the designated time frame
• Performing ongoing research for any regulatory changes
• Recommending changes to the BSA policy when necessary
• Reviewing the exempt list, and performing quarterly reviews of accounts on the list
• Assisting the development of an effective training program and monitoring its progress for quality and effectiveness
• Confirm that records are available and in compliance with the Recordkeeping Requirements on Cash purchases of monetary instruments between $3,000 and $10,000, and that these records are readily accessible.

• All cash deposits and withdrawals exceeding $10,000 or multiples totaling more than $10,000 made during the credit union's business day, including night deposits
• All transactions exceeding $10,000 made by different individuals for the same account holder on any given business day
• Personal and business transactions exceeding $10,000 in cash for cash (exchanging $20 bills for bills of a higher denomination)
• Cash back transactions exceeding $10,000 whenever a member cashes over $10,000 in checks
• Purchases of negotiable instruments for an amount of $10,000 or less when an added service fee increases the total to more than $10,000 and the total amount is paid in cash

• Checks cashed
• Deposits made to:
  • Share draft accounts
  • Share savings accounts
  • Share certificate accounts
• Loan payments
• The purchase of credit union official drafts
• Wire transfers
• The purchase of travelers checks
• The purchase of U.S. Savings bonds
• For treasury tax and loan payments
• Purchase of securities
• Any other payments or deposits
• All other cash-out transactions

• Insider abuse involving any amount. Exempted from this requirement are robberies or burglaries that have otherwise been immediately reported to law enforcement authorities and losses incurred as a result of lost, missing, or stolen securities falling under other filing requirements.
• Violations aggregating $5,000 or more where a suspect can be identified, including any transaction involving funds from illegal activity or where an attempt is made to disguise funds from such activities; any transaction where an attempt is made to evade BSA requirements' and transactions that seem to have no business purpose or are at variance with normal activities of the party making the transaction.
• Violations aggregating $25,000 or more with out regard to a potential suspect.

• Structuring/money laundering (as defined in the Bank Secrecy Act)
• Bribery or gratuity
• Check fraud
• Consumer lending fraud
• Check kiting
• Counterfeit checks
• Counterfei debit cards
• Other counterfeit embezzlement
• False statements
• Misuse of position or self dealing
• Mortgage loan fraud
• Mysterious disappearance
• Wire transfer fraud

• Payment order - an instruction by a sender to a receiving bank or credit union, transmitted orally, electronically, or in writing, to pay or cause antoher bank or credit union to pay, a fixed, determinable amount of moeny to a beneficiary. The instruction must contain a condition to the payment except for the timing of the payment; the receiving bank or credit union is to be reimbursed by debiting an account of, or otherwise receiving payment from, the sender; and the instruction is transmitted by the sender directly to the receiving bank or to an agent, funds transfer system, or communication system for transmittal to the receiving bank or credit union.
• Funds transfer - a series of transactions made for the purpose of making payments to the beneficiary of the payment order. Excluded from this definition are all transfers governed by the Electronic Fund Transfer Act (Regulation E) and transfers made through an automatic clearinghouse, an automated teller machine (ATM), or point-of-sale (POS) system.
• Originator - the individual giving the instructions to the receiving financial institution for the payment order in a funds transfer transaction.
• Beneficiary - a person to be paid by the financial institution.
• Receiving bank - the bank or credit union to which the sender's instructions are addressed.
• The credit union will adhere to the recordkeeping requirements in cases where the credit union is the originator of the funds transfer and the transfer amounts to $3,000 or more.
• The wire transfer department will retain for a period of five years the following records for funds transfers for all transactions accepted as an originator "bank." These records will be retained as an original or a microfilm, other copy, or electronic record:
• The name and address of the originator
• The amount of the payment order
• The execution date of the payment order
• Any payment instructions received from the originator with the payment order, to include oral or written instructions, the purpose of the fund's transfer, directions to the beneficiary's bank regarding how to notify the beneficiary of the receipt of the funds (e.g., advise by phone), or other information
• The identity of the beneficiary's bank
• As many of the following items as are received with the payment order; the name and address of the beneficiary, the beneficiary's account number, plus other specific identifiers relating to the beneficiary

• A domestic financial institution
• A wholly owned domestic subsidiary of a domestic financial institution
• A domestic broker or dealer in securities
• A wholly owned domestic subsidiary of a domestic broker or dealer in securities
• The United States
• A state or local government
• A federal, state, or local government agency
• Where both the originator and beneficiary are the same person and both the originator's and the beneficiary's financial institution are the same domestic financial institution

• Other U.S.financial institutions
• Federal, state or local governments
• Most publicly traded corporations (nonprofit organizations such as universities and hospitals are still covered by CTR requirements)
• A qualified business customer who has maintained a transaction account at the credit union for at least 12 months, who frequently makes transactions in currency with the credit union in excess of $10,000 and is incorporated or organized under the laws of the U.S. or a state, or is registered and is eligible to do business in the U.S. or a state
• Payroll members that withdraw cash for payroll purposes from exisiting transaction accounts provided they have maintained a transaction account at the credit union for at least 12 months, operate firms that regularly withdraw ,pre tjam $10,000 to pay their employees in currency, and are incorporated or organized under the laws of the U.S. or a state, or are registered and is eligible to do business engaged in:
  • The practice of law, accountancy, or medicine
  • The auctioning of goods
  • The chartering or operation of ships, buses or aircraft
  • Gaming of any kind (other than licensed betting at race tracks)
  • Investment advisory services or investment banking services
  • Real estate brokerages
  • Pawn brokerages
  • Title insurance and real estate closings
  • Trade union activities

1. Less risk of identity theft.
2. Reduced risk of check fraud.
3. Increased safety from fraud for the credit union.

• Account. Each formal banking or business relationship that provides ongoing services, dealings, or other financial transactions.
• Customer. Any person seeking to open a new account. This includes established members seeking to open a new account or sub-account as well as the non-member seeking to open an initial share account to join the credit union. Customer also includes any signatory to an account.
• Person. Any legal personality such as individuals, trusts, estates, partnerships, corporations, associations, syndicates, joint ventures, certain Indian Tribes, and other unincorporated organizations or groups.

1. for U.S. persons, a U.S. taxpayer identification number (e.g., social security number, or individual taxpayer identification number);
2. For non-U.S. persons, a U.S. taxpayer identification number and a passport number and country of issuance and an alien identification number bearing a photograph or similar safeguard.

• 1. Current photo ID with DOB, address and TIN
  1. Driver's License, or
  2. State identity card, or
  3. Military identity card, or
  4. Similar Municipal, State or Federally issued identity card
• 1. Combination documentation of identity
  1. Photo ID (Passport), and
  2. Social Security card or similar proof of TIN, and
  3. Copy of birth certificate
• Note: Photo ID of infants is not required for accounts opened on the child's behalf. Elderly members may not have a valid driver's license or other form of identification. Staff should handle these situations on a case-by-case basis with the assistance of the Manager/CEO or the Head bookkeeper.