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1.
We would like clarification on why aliases found on the OFAC Sanctions list do not result in True-Positives when searched using Tool 778 (Scan a Single Name Through OFAC). Reviewing the "Using the CU*BASE Data Match System for OFAC Compliance" resource, it states that AKA names are searched. Evidently there are two AKA lists, one embedded in the SDN Comments Section and a separately published list.
This is what FinCEN has stated in the past about weak aliases: Am I required to screen for weak aliases (AKAs)? OFAC’s regulations do not explicitly require any specific screening regime. Financial institutions and others must make screening choices based on their circumstances and compliance approach. As a general matter, though, OFAC does not expect that persons will screen for weak AKAs, but expects that such AKAs may be used to help determine whether a 'hit' arising fro More...
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2.
What is a Source of Receipt and how do I get a copy of one?
Source of Receipt (SOR) is the paperwork that accompanies the checks to the Check Processor. It is the documented proof of when and from whom the checks were received. SOR provides the ABA# of the bank the checks are received from, the date of the cashletter, the amount of the bundle the check was in, the position of the check in the bundle (checks before after), and the tracer number assigned to the check. On the form you'll see a couple of abbreviations: IB stands for Item Before that More...
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3.
I received a notification that there are changes being made to CTR forms. In August 2017, new fields are being added to CTR forms that are required to be in compliance. What is CU*Answers doing to be in compliance with these changes?
You are referring to this announcement released by FinCEN in May. We currently have a project sheet (#45201) to comply with these required changes. NOTE: The deadlines refer to when FinCEN will begin being able to receive the new data, not the date when the new data must be sent. We continue to track this project with FinCEN and will alert clients when changes have been made that will affect their day-to-day activities.
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4.
We would like to locate information on the number of tax files sent to the IRS for our members. Where would we find this information?
The reports on you would be looking for are the P1099*, P1098* and P5498* reports. These reports are sent to CU*Spy when we send the files to the IRS. They are bundled with the Daily Reports for that day. If the P1099* and P1098* reports are no longer in CU*Spy, you may need to look at your March Reports CD. The P5498* reports should be in CU*SPY or on your May Reports CD. We also send these reports to a credit union's inhouse eDOC server if you have one. The Tax CD you receive contai More...
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5.
How do GOLD updates work?
The update process consists of three steps: Get the update package from CU*Answers Unpack the update package Update the PCs at your site Files are created by our programming team that need to get to you when it is time for an update. The combined size can be very large. To reduce the size, the files are bundled and compressed. The resulting package is placed on a server here at CU*Answers. You contact that server and retrieve the update package using either a GUAPPLE device or shortcuts that you More...
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6.
Is e-signing for loan documents the same thing as Packages from eDOC Innovations?
No, this is completely separate. With this free eSignatures solutions, all forms must be sent one at a time and are tracked independently as already described. If you have an in-house vault or are interested in a more sophisticated solution for bundles of multiple forms, contact Imaging Solutions and ask about Loan Packages.
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7.
How do I use CU*BASE tools to keep track of the beneficial owners on my business accounts and other memberships?
Using CU*BASE to Comply with New Rules for Tracking Beneficial Ownership FinCEN has issued new rules under the Bank Secrecy Act that require financial institutions to identify and verify the identity of the beneficial owners of all legal entity members (corporations, etc.). Under the final rule, credit unions are required to have written procedures to identify and verify beneficial owners of legal entity members who open new accounts on or after May 11, 2018. In addition to identifying and coll More...
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8.
This is my first time completing the ‘Fedline Solutions Security & Resiliency Assurance Program’ required by the Federal Reserve done annually. This, in part attests that we are in compliance with Operating Circular 5. Is CU*Answers considered a Third Party Service Provider (item processing, ACH transactions, etc.? If so, is there any type of documentation that I can obtain showing that you are in compliance with Operating Circular 5?
Yes. You can find a copy of the signed letter of attestation that CU*Answers has completed the annual assessment of the FedLine Solutions Security and Resiliency Assurance Program via our Due Diligence site at cuanswers.com.
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9.
We attended a web conference on the many compliance configurations on the system. How can I view a recording of this training?
You will find the Using CU*BASE Tools for Bank Secrecy Act Compliance on the On Demand website. See the link below.
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10.
Does the incoming ACH posting file have to have an OFAC scan performed on the originators in order for the credit union to be compliant?
OFAC is defined in the NACHA Operating Rules and Guidelines Chapter 3, Section 1 pages OG15-OG21. There is a difference between OFAC procedures for ACH transactions and the verification of parties with which a financial institution does business. For ACH purposes, only the addenda information on cross border transactions (IATs) require an OFAC scan for both RDFIs (receiving depository financial institutions) and ODFIs (outgoing depository financial institutions). As far as OFAC compliance goes More...
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11.
Do the Deposit Secured loan products require that joint owners sign documents? Does it evaluate loans against community or marital property laws?
No. Secured loans do not look to joint owners, community property, or marital property laws. The loan documents will not require, ask for, or accept a second signature. Your credit union may wish to review your Member/Loan Documentation to ensure they are still in compliance with the product. You may decide to use a unique certificate type for CD Secured loan products or a unique dividend application for your Share or Share Draft Secured loan products.
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12.
What is Metro 2?
Simply put, Metro 2 is a new standard electronic data reporting format that is used to report credit data to all of the credit reporting agencies (TransUnion, Equifax, Experian, and CBC/Innovis). Designed to foster the reporting of complete and accurate data to the credit bureaus, the Metro 2 Format also addresses FCRA (Fair Credit Reporting Act) compliance issues. Using a consistent reporting format for all bureaus will make it much more efficient to report data, especially for credit unions More...
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13.
What is Audit Link?
The Audit Link service consists of three interrelated business activities. The first is an overall analysis of the credit unions needs, hot buttons, and recent audit or examination findings. This analysis is designed not only to tailor the program for the credit union but also to facilitate an overall general compliance tune-up. The second area of this initiative is the development of a daily, monthly, and quarterly roadmap of tasks to be completed. This is where the credit union would see the More...
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14.
If a credit union becomes an Originator (not ODFI), will this expand the scope of the credit union’s annual audit?
More information can be found in Chapter 13 “ODFI Audit Requirements and Rules Compliance” found on OG52 of the NACHA Operating Rules. The first sentence in Chapter 13 states: All ODFIs, Third Party Service Providers performing a function of ACH processing on behalf of those ODFIs, and Third Party Senders must perform an annual audit to determine compliance with all provisions of the NACHA Operating Rules. Third Party Service Providers and Senders are very well defined in t More...
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15.
What is the ACH posting change required by the Federal Reserve Board (FRB) on 9/20/19?
Answer: The FRB requires that same-day credit items received in the 12:00pm ET file window are posted no later than 1:30pm ET. This will require a new ACH posting configuration from CU*Answers. That configuration was added to the software in the May release and will be made available to you no later than 9/9/19. CU*Answers Operations will begin bringing the 12:00pm ET FRB files in earlier beginning 7/22/19 in preparation for this change. CU*Answers plans to populate the configuration to “P More...
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16.
My auditors have questions about OFAC scans. Where can I go to get answers?
Direct auditors with questions about OFAC scans to the Using the CU*BASE Data Match System for OFAC Compliance reference booklet, available on the CU*BASE Reference page. Click below to access a direct link to the booklet.
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17.
I have a new BSA Officer. Where is a good place to start with them?
The team at AuditLink performs daily monitoring activities on behalf of credit unions to assist in the fulfillment of Bank Secrecy Act (BSA) compliance requirements. The same procedure guide their team uses to do this work is now available to credit unions. Click the link below to order the free Daily and Weekly Procedures guide from AuditLink.
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18.
Why does the APY quoted using the CU*BASE APY calculator not match the APY printed on the actual TIS form for a member's certificate?
Because the APY calculator on CU*BASE uses the Minimum Balance configured for that CD Product to perform the calculation. It does not know the member's certificate balance and term. The TIS form calculation is based on the ACTUAL balance of the CD and it annualizes the CD Term. The variance is within compliance tolerance, usually no more than 0.01%.
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19.
Why did the APYE disclosure not appear on our first statement run with CU*Answers?
The APYE calculation depends on the date of the last statement run (both monthly and quarterly). Because you are a new client, that data is not present. The results of the APYE calculation are then extremely skewed. We feel is it prudent not to display the disclosure statement with invalid information. You are still in compliance for this one statement run given the circumstance of changing to a new data processor. APY mailing TIS Truth-In-Savings dividends
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20.
I understand that when considering a job applicant, we can request a credit report to help in our decision to hire. Can we use our on-line credit bureau feature in CU*BASE to retrieve this report?
No. In the instance of a job screening process, the format for the credit report is significantly different than a credit report used for a lending decision. Your first step is to insure that the job appplicant knows and agrees that the report will be reviewed. You can contact your credit bureau processor (Equifax, Trans Union or Experion) to gain access to their web-based product that will keep you in compliance.
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21.
How is forward cash collection different from the image archive service?
Forward cash collection allows your credit union to realize the full benefits of Check 21 by performing total electronic deposit automation. CU*Check 21 allows your credit union to streamline operations by combining encoding, endorsing, filming, bundling and transporting deposit items into a single step. By using CU*Check 21 for forward cash collection, your credit union eliminates the need to send most physical items for collection.
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22.
Where can I find the USPS form 6014 Certification of
Move Update Compliance? The credit union CEO needs to complete, sign, and send that form to our Mail Preparer, (e.g. Sage Direct, Inc.) This is an annual task that will need to be done by late November each year.
We have a sample form and a blank form for 2008 stored on our website: www.cuanswers.com Click I Am A Client. Or use the link below http://www.cuanswers.com/client_special_interest.php#tasks A blank form can be obtained from http://www.usps.com/forms/_pdf/ps6014.pdf
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23.
What are the requirements for a "from" email address in CU*BASE? How do I change my "from" email addresses?
Credit union FROM email addresses are closely regulated and monitored within CU*BASE. As a mass email sender, and as an entity that sends on behalf of the network of credit unions, CU*Answers must meet standards of compliance set forth by email service providers, such as Google and Yahoo. Many of these standards rely on our email being delivered to appropriate and accurate member emails, from correctly configured credit union emails. If we fall out of compliance with these standards, we run the More...
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24.
What is VoIP?
Short for V oice o ver I nternet P rotocol , a category of hardware and software that enables people to use the Internet as the transmission medium for telephone calls by sending voice data in packets using IP rather than by traditional circuit transmissions of the PSTN. One advantage of VoIP is that the telephone calls over the Internet do not incur a surcharge beyond what the user is paying for Internet access, much in the same way that the user doesn't pay for sending individual e-mails over More...
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25.
I am looking for any documentation that states that CU*Answers is in compliance with the Gramm-Leach-Bliley Act. Where can I find this?
The Gramm-Leach-Bliley Act refers to member privacy and data integrity for financial institutions. Your credit union's contract with CU*Answers includes verbiage pertaining to member privacy and data integrity. Should you have an older contract that does not include this verbiage, you can contact a member of our Sales/Marketing Team about receiving an updated contract. For additional information, including CU*Answers SAS70 and Data Security policy, please contact a Client Service Representative.
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