( COMPLIANCE HOTLINE 443-325-0777

For compliance and regulatory concerns please contact our staff directly on our Compliance for courteous, prompt assistance.

BANK SECRECY ACT—Compliance Assistance for member Credit Unions

MDDCCUA features qualified individuals available to assist you with your credit union’s BSA program.  We offer assistance to our affiliated credit unions in the following areas:

1. Training – Qualified staff is available to visit your credit union to provide the required annual BSA/AML training for the credit union’s staff, board, and volunteers.
2. BSA Review and Testing – Qualified staff is available to conduct your credit union’s required annual BSA Review and Program Testing.  The components of the BSA Review and Testing include but are not limited to:

•     An evaluation of the overall integrity and effectiveness of the BSA/AML compliance program, including policies, procedures and processes.

•    A review of the Member Identification Program (MIP) to verify the credit union’s adherence to proper identification and Office of Foreign Assets Control (OFAC) requirements.  

•   A review of the credit union’s risk assessment for reasonableness given the institution’s risk profile (products, services, members, and geographic locations).

•  Appropriate transaction testing to verify the credit union’s adherence to the BSA record keeping and reporting requirements (such as MIP, SARs, CTRs, CTR exemptions and information sharing requests).

• An evaluation of management’s efforts to resolve violations and deficiencies noted in previous audits and regulatory examinations, including progress in addressing outstanding supervisory actions, if applicable.

•  A review of staff training for adequacy, accuracy, and completeness.

• A review of the effectiveness of the suspicious activity monitoring systems (manual, automated or combination) used for BSA/AML compliance. Related reports may include but are not limited to:

o       Suspicious activity monitoring reports.

o       Large currency aggregation reports.

o       Monetary instrument reports.

o       Funds transfer records.

o       Nonsufficient funds (NSF) reports.

o       Large balance fluctuation reports.

o        Account relationship reports.

·         An assessment of the overall process for identifying and reporting suspicious activity, including a review of filed or prepared SARs to determine the accuracy, timeliness, completeness, and effectiveness of the credit union’s policy.

·         A review of filed or prepared CTRs to determine the accuracy, timeliness, completeness, and effectiveness of the credit union’s policy.

The BSA/AML Review and Testing is currently limited to single branch credit unions, and the cost for this service is determined by the credit union’s asset size.

Other Compliance and Operations Services Available

MDDCCUA’s “Compliance Hotline” provides direct access to staff where credit union’s can receive speedy responses to questions.  With the available resources, staff is prepared to conduct research and provide compliance assistance in many areas to include but is not limited to:

·         ACH Transactions

·         Bankruptcy

·         Expedited Funds Availability

·         Fair Credit Reporting

·         Fair Debt Collection

·         Identity Theft

·         IRS Reporting – 1099-C

·         Truth in Savings

·         Record Retention

·         Servicemembers Civil Relief Act

·         Truth in Lending

·         Uniform Commercial Code

Maryland and District of Columbia credit unions can receive top-notch support in the area of Collections.  MDDCCUA staff members are available to:

·         Review Collection policies and procedures

·         Provide an on-site review of the credit union’s current collection process and work flow.

·         Conduct collection training for new and current staff.

·         Review current telephone techniques.

·         Review current collection letters used.

·         Provide repossession guidance

·         Provide collateral disposition guidance

·         Answer questions concerning accounts involved in Bankruptcy.

Other Collection Resources Available

www.blackbookusa.com – Provides vehicle values for auction prices.

www.accurint.com – Provides skip-tracing assistance for members who have relocated.

Credit union’s can also benefit from MDDCCUA’s hosting and list-server functions that support several credit union roundtables that allow lending, collections, and compliance staff – among others – to exchange information and ideas online.

Helpful Links

Credit Union National Association (CUNA) eGuide

Federal Reserve

Federal Register

National Credit Union Administration (NCUA)

U.S. Federal Judiciary

U.S. Department of the Treasury

State of Maryland Resources

Maryland Department of Financial Regulation

Maryland Department of Insurance

Maryland's Abandoned Property Rules

Maryland Judiciary

State of Maryland Code of Regulations

Maryland and District of Columbia Credit Union Association
8975 Guilford Road, Suite 190 • Columbia, MD  21046
phone: (800) 492-4206 • fax: (410) 290-7832