Bank Secrecy Act (BSA) (supplemental front-line training)

Bank Secrecy Act (BSA) Topics Suspicious Activity Report (SAR) Monetary Instrument Log Currency Transaction Report (CTR)

Suspicious Activity Report (SAR) In general, we must file a SAR for transactions... involving funds derived from illegal activity; intended to hide or disguise funds derived from illegal activity; designed to evade the requirements of the BSA; that appear to have no business purpose or that vary so substantially from normal activities appropriate for the particular member as to have no reasonable explanation.

Suspicious Activity Report (SAR) After becoming aware of suspicious activity, a SAR must be filed within 30 calendar days. We may not inform the member a SAR will be filed. Actually, no one needs to know except you and Sarah Boyer, Kemba’s Compliance Officer. SARs at Kemba are located on the Intranet under the Documents/Forms tab. Forward completed SAR to Sarah Boyer. Please be sure to include a description of the suspicious activity in the narrative section.

Monetary Instrument Log Credit unions are required to keep certain records of transactions involving the purchase of monetary instruments (credit union checks, cashier checks, money orders, & travelers checks) with $3,000 - $10,000 in currency. Each branch has a log with the following info... date of purchase member’s name and account number type of instrument(s) purchased serial # of each instrument purchased dollar amount of each instrument purchased Identification (list issuing state and ID #); if member is known to teller performing transaction, may check “known” instead

Monetary Instrument Log Recordable Transactions Only write required transactions in the Monetary Instrument Log. The following constitute a required transaction: a person brings in an aggregate of $3,000 through $10,000 in cash during a business day and purchases one or more of the following items with these funds: Kemba Official Check Kemba Cashier’s Check Money Order Traveler’s Check IMPORTANT: If you deposit the funds into the member’s account then perform a withdrawal of these funds to issue the member a monetary instrument, such a transaction would be included on the log.

Monetary Instrument Log Non-Recordable Transactions Please do not record any non-required transaction on the Monetary Instrument Log. For example, none of the following should be listed on the log: Straight Cash Withdrawal Straight Cash Deposit Straight Check Withdrawal Cashing a Check

On Whose Behalf Conducted CURRENCY TRANSACTION REPORT (CTR) Getting to Know the CTR Person(s) Involved in Transaction Part I, Section A: On Whose Behalf Conducted Occupation must be specific Must obtain ID info regardless of whether you know member and must record this info on the CTR Make copy of ID and send to Sarah Boyer along with completed CTR

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Getting to Know the CTR Person(s) Involved in Transaction Part I, Section B: Who is Conducting Transaction (if different from Section A) If conducted on own behalf, must check that box If conducted on behalf of another (for example, conducted by a Power of Attorney)... Must obtain ID regardless of whether you know individual conducting transaction and record info on CTR Make copy of ID and send to Sarah Boyer along with completed CTR

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Getting to Know the CTR Amt & Type of Transaction Part II: Please be sure to include date of transaction Amount always should be rounded up For example, $10,152.07 = $10,153 Boxes 30-34 & 36 (at least one of these boxes needs to be checked; if box 36, describe the “other.”

Getting to Know the CTR Amt & Type of Transaction (Part II, cont) Box 35 (Acct Numbers affected, if any) Examples: A person cashes a check drawn on an account held at Kemba: indicate negotiable instrument(s) cashed and provide the account number of the check. A person cashes a check drawn on another financial institution: indicate negotiable instrument(s) cashed but leave box 35 empty because no account at the financial institution has been affected.

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Getting to Know the CTR Financial Institution Information Part III: some fields are already populated on the CTR form located on Kemba Intranet Address should be branch where transaction occurred Approving official...preferably Branch Supervisor or Branch Manager; head teller if supervisor not available Date of signature Type form; if need to handwrite: PRINT NEATLY

Multiple Persons Joint Accounts: All account holders present at transaction should be included on CTR. All account holders should be included on CTR even if not present at transaction. (This requirement applies to both deposit and withdrawal transactions.) Exception: you have specific information that transaction only benefits account holders conducting transaction. You will need to supply Compliance Officer with a summary of this information.

Multiple Persons (joint accts-cont) The account holders are listed in Section I, Part A. Use the continuation page(s) if more than one account holder. Account holder is not listed in Part B of Section I. Obtain occupation of account holders not present at the transaction. For account holders not present...under ID portion, check the “other” box and type “N/A” on the line.

Summary Review of CTR Account holders are listed in Part A and not Part B. All account holders must be listed unless exception applies. Occupation must be specific. For example, “self-employed” is not acceptable. “Self-employed builder” is acceptable. ID must always be obtained and recorded for person(s) conducting transaction regardless of whether known to teller. Double check completed CTR, then forward it to Compliance Officer, Sarah Boyer. (CTR must be filed with gov’t within 15 days.) If member is conducting transaction on own behalf, be sure to check that box in Part I, Section B. Part II-Amt & Type of Transaction: if you check the “other” box, a description is required on the corresponding lines.

QUESTIONS Please contact Sarah Boyer, extension 1897, if you have any questions.