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...

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...

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.

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...

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...

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...

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.

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.

You will find the Using CU*BASE Tools for Bank Secrecy Act Compliance on the On Demand website. See the link below.

CNS is a trusted partner of our credit unions and often we are the first call when there’s a cyber event at an institution. However, there are important limitations to the cybersecurity services that CNS provides. CNS provides general office network design, implementation, and management services. CNS will monitor and patch for supported patches . CNS does not provide cyber security services. CNS does not warrant that managed networks are immune to cyber events or breaches or that lost dat  More...

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...

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.

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...

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...

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...

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...

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...

If you are a federally chartered credit union, enter the words “Overdraft fee” in this field to remain in compliance. This is because that description is what is used on the fee summary disclosure on the statement, and federally-chartered credit unions must use this specific terminology. • NOTE: If you are adjusting your description, you may also want to include a statement message to alert members to the change.

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.

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

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.

At this time due to compliance reasons business accounts cannot be set up with P2P processing. We are looking at allowing this feature in the future but do not have a ETA at this time.

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%.

Many CNS Complete Care network management clients are securing the services of third-party network security vendors to provide cyber security management and oversight of their networks. CNS strongly recommends that all Complete Care managed clients have a third-party security operations center vendor (sometimes known as a SOC) that specializes in cyber security monitoring and alerting, as the Complete Care management service is not a cyber security management service. CNS can assist your credit   More...

Microsoft has thousands of products, and we do our best to help our client-owners maximize their utilization of what Microsoft offers. However, there are important limitations you should understand regarding the service CNS is able to offer related to these products. As a cooperative, we pool owner resources to bulk buy solutions and offer them to you at the lowest prices we can. We do not charge separate management fees for Microsoft products, which keeps your costs for them as low as possible.  More...