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CIP Idnetification presented
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I am in the process of auditing our BSA program. Upon examining the new membership applications, we require at least two forms of identification. Primary must be a government issued identification and a secondary form of identification. I am observing, “Work ID” or Work Paystub” as the second form of identification.  No note as to the identification of the employer. If requested, how can we produce evidence of the secondary identification if we do not list an employer on the application nor a work telephone number.

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Plastic Card Audit
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We have concluded our exam. The examiner would like us to have an annual review of our plastic card program as required by state regulations. Has anyone performed this audit? Looking for some guidance. Thanks as always. Beronica.Noriega@R1CU.Org

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SAFE Act Audit Deadline
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I know that independent testing of SAFE Act compliance is to be completed at least annually. I was anticipating performing this audit after the one year anniversary of the 7/29/2011 deadline with the thought process being that one year has been completed. However I received an email from a webinar that I attended stating that "The regulators set July 29, 2012, as the deadline for your SAFE Act annual, independent compliance test." I've been researching to see where this "Deadline" date is but can not find anything that states this. How is everyone else handling this first audit?

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Vulnerability Assessment Reporting
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When you have an internal or external vulnerability assessment and/or penetration testing, do you review the reports? What do you do with the reports? Do you have a checklist you use to help review the reports?

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FinCEN: Customer Due Diligence Requirements for Financial Institutions
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We have been asked to give our opinion and submit a comment to this ruling. What are your thoughts? Do you think this is going to create extensive work or be a benefit to the credit union world? 

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Advertising
Forum topic

I have been asked to look at some advertising pieces that are ready to get printed. However, I have not done an audit in this area. I have gone to Texas Credit Union League and pulled the information pertaining to Advertising. Do you audit this area? If so, what are your recommendations? Thanks in advance.

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CPA Auditor Rotation/Retention
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Hello,How often does your credit union switch CPA firms for the annual opinion audit? Since current regulations do not require credit unions to switch firms after a set number of years, I would like to get some feedback on what other credit unions are doing in the industry.  I ask this because our friendly neighborhood examiner suggested we switch firms to gain “new prospective”, but we have only been with our current firm for three years. I would really appreciate some input on this.

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Teller Testing
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I'm looking for some opinions...We have cash machines at most of our locations.  Recently there has been some shortages on a particular machine. Has anyone ever done testing for dishonesty by adding extra money to a machine (or drawer or vault) to see what will happen? This is a suggestion from management and I'm wondering if this is common practice?

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Wire Transfer and Reg J Disclosure
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Hi,Could someone direct me in Reg J where I can find how our member is supposed to receive the REG J disclosure?  We have had it attached to the back of our Wire Transfer form in the past so the member would receive it every time they did a wire.  Now management wants to know if it can be disclosed at account opening only, as we have gone to an automated wire transfer system.I looked through the FRB book REG J tab and could not find how often this information needs to be given to the member.ThanksBeverly McMahon;  Senior Auditor, Century Federal Credit Union  

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Supervisory Committee members
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I'd like to hear opinions on whether the Supervisory Committee Chair, who is also a member of the board of directors, should be allowed to serve on the ALCO committee.  I know it is not specifically prohibited by NCUA, but in my opinion, it is not a best practice and could present potential conflicts of interest.  Any thoughts and opinions are welcome.  Thanks for your input.

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