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Latest News: Compliance

Compliance Q&A: Currency Transaction Reports, Criminal Background Checks, Delinquent Loan Reporting

Thursday, August 29, 2013   (0 Comments)
Posted by: Leah Redding
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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?

Answer: 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?  

Answer: 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 information.  

However, 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.  

Recently, 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.  

For more information regarding hiring policies please contact an HR attorney or other employment professional.        

Call Report Delinquent Loan Categories FAQs  

The 2013 loan delinquency reporting changes are addressed in a set of Frequently Asked Questions issued by NCUA [.pdf].

This document addresses:  
  • How has the Call Report delinquency categories changed?
  • Why did NCUA clarify the delinquency categories?
  • Must credit unions change how they calculate delinquency?
  • Do grace periods affect how delinquency should be reported?
  • What goes into the delinquency ratio?
  • Will there be seasonal variation in delinquency ratios?
  • Do examiners understand the potential seasonal variation in delinquencies?