REQUIRED INFORMATION FOR CREDIT UNION BOARD CHAIRMEN AND MANAGEMENT
Board Approves Proposed Rule to Allow Exemptions from SAR Requirements
ALEXANDRIA, Va. (Dec. 23, 2020) – The National Credit Union Administration Board unanimously approved, by notation vote, a notice of proposed rulemaking (opens new window) that would amend the agency’s Suspicious Activity Report (SAR) regulation.
The proposed regulation would permit the NCUA to issue, on a case-by-case basis, exemptions from SAR filing requirements to federally insured credit unions, when the exemption is consistent with safe and sound practices and can improve the effectiveness and efficiency of Bank Secrecy Act reporting. The proposed rule would also make it possible for the NCUA to grant exemptions, in conjunction with the Financial Crimes Enforcement Network, to federally insured credit unions that develop innovative solutions to meet Bank Secrecy Act requirements.
The NCUA expects these amendments will reduce regulatory burdens on federally insured credit unions and encourage technological innovation within the credit union system.
These proposed changes are part of a coordinated effort between the NCUA, FinCEN, and the federal banking agencies to improve the efficiency and effectiveness of Bank Secrecy Act compliance programs and facilitate greater innovation within the banking sector.
Comments on the proposed rule (opens new window) will be accepted for 30 days after publication in the Federal Register.
When a credit union employee suspects a member may be subject to fraud, they should initiate a careful conversation focusing on the nature of the transaction and external influences. The goal is to help the member identify red flags without the employee asking for sensitive personal information that the credit union should already have on file. Initial Verification Questions .pdf Before discussing the specifics of the suspicious activity, the employee should confirm the member's identity in accordance with established internal protocols. Questions About the Transaction/Activity If the member confirms they are conducting a suspicious transaction (e.g., a large wire transfer or purchase of gift cards ), the employee should ask questions to help the member pause and think critically: "What is the purpose of this transaction?" "Do you personally know the person or business you are sending money to?" "Have you ever met the...
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