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NCUA BSA Hot Topics

I had the pleasure last week of speaking at and attending CUNA’s Bank Secrecy Act Conference in Dallas.  I was hoping to come away with some useful information to bring back to my credit unions. As usual, I was not disappointed.  Judy Graham from the NCUA provided credit unions with some valuable information on the BSA “hot topics” during its examinations. Here is a little summary:

Independent Testing:

  1. Ensure your credit union’s BSA independent testing is truly “independent.”
  2. Ensure your independent tester is qualified and looks at the overall effectiveness of your BSA program.
  3. Ensure that you have an independent test completed every 12-18 months depending on your risk.

Internal Controls:

  1. Is your risk assessment an adequate reflection of your credit union’s risk?
  2. Accuracy of CTR and SARs.
  3. Are you filing your BSA forms electronically?
  4. Do you have the proper reports to ensure you are monitoring for reporting requirements and suspicious activity.

BSA Officer:

  1. Does the credit union have a back-up BSA Officer so that oversight of the program continues even when there is an absence?


  1. Are training materials up-to-date?
  2. Is training done on at least an annual basis?
  3. Is the training documented?

I always find it very interesting to get to listen to FinCEN, the NCUA, and others. However, I would have to say that the most enjoyable part is getting to meet all of the wonderful individuals who are responsible for BSA programs around the country. It reminds me of just how much I enjoy working with credit unions.

Have a great weekend.

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