Currency Transaction Reports: Cash out from credit card
A member received cash out over $10,000 from their MasterCard credit card; do I
complete a CTR for this transaction?
Yes, a CTR should be completed and according to FinCEN, since item 22 is not a
required field, you can leave it blank. Putting in the credit card account
number is acceptable as well. However, FinCEN suggests not listing the actual credit union
savings account number, since the account wasn’t involved in the transaction.
Criminal Background Checks
Are we allowed to do criminal
background checks as part of our hiring policy?
Appendix A to NCUA’s
Part 748 (guidelines for safeguarding member information) states that when
developing a security program, the credit union should have procedures in place
to safeguard member information, including conducting employee background
checks on those employees with responsibilities for or access to member
while there is no general protected status for convicted criminals, the Equal
Employment Opportunity Commission (EEOC) has warned that they believe that some
employers use criminal background checks as a way to weed out minority
employees and applicants who tend to have higher conviction rates.
the EEOC sued two companies over their use of criminal background checks. In
one of the lawsuits, the employer fired 88 workers (70 of them
African-American) after they failed criminal background checks. Some of these
employees had worked for the company for several years without an incident. The
other case involved claims by two African-American job applicants who were
denied work, one for a six year old conviction for use of a controlled
substance. The EEOC argues that such blanket exclusions from employment are
improper because they do not consider the nature of the involved offense and
its relevance to the job.
information regarding hiring policies please contact an HR attorney or other