FARMERS BRANCH, Texas – A Bank Secrecy Act Compliance Training DVD and a 26-page training packet was mailed in early March to credit unions that have paid their annual membership dues to the Texas Credit Union League. The complimentary training production provides an hour-long overview of the various requirements of the Bank Secrecy Act and USA PATRIOT Act, including Currency Transaction Reports, Suspicious Activity Reports, the Customer Identification Program and risk assessments. The video features the expertise from three league officials: Suzanne Yashewski, vice president of regulatory, compliance & legal affairs; Carolyn Merchan Saegert, associate general counsel, and Steve Gibbs, director of compliance services. Their collective understanding of the numerous details of the regulation is concisely presented. Small vignettes acted out by credit union and league staff dramatize potential situations and lend bits of humor to a serious topic. TCUL’s Senior Vice President Bob Gallman even has a cameo appearance in a wig and sunglasses. Using the accompanying training materials, viewers will quickly learn specific situations to watch for in order to comply with the regulations. The written materials, which include all necessary forms, can be photocopied and distributed to front-line staff. The back page is a form for employees to sign after they watch the video. The credit union can keep copies on file to show regulators that the credit union has trained its employees. “The Act requires financial institutions to train staff at least once annually. AmSouth Bank paid $50 million in fines for BSA violations; Riggs Bank paid $17 million. One violation in both these instances was failure to train staff,” Gibbs said. “Could a $50 million credit union sustain fines of $2-$5 million for this type of violation? It would come out of every member’s pocket.” Gibbs, who called the USA PATRIOT Act the “biggest financial regulation in 20 years,” advocated showing the video to the entire staff, including full management, as well as the credit union’s board of directors. “Credit unions should know which areas apply to particular staff and test those individuals to be sure they know the material,” he said. Financial institutions are also required by the Act to have a designated compliance officer. Gibbs estimated that only one-third of Texas credit unions currently have a full-time compliance officer. Size prevents many from staffing an additional position, and for those, Texas Credit Union League is in the process of rolling out a shared compliance officer program. Through the program, a compliance officer employed by the league would spend several days a month in the credit union and be available on an on-call basis the remainder of the month. That officer’s time would be shared with other credit unions unable to staff a full-time compliance officer. “We’ll be hiring other compliance officers as credit unions come onto the program,” Gibbs said. Georgia Credit Union & Affiliates is the only other league currently offering this service, according to Gibbs. The Texas league is promoting “The Value of Membership” as its theme this year. The BSA production was sent as a thank you to credit unions that paid their dues by Feb. 28. “This valuable benefit reminds members that their dues dollars are well-spent. People are so concerned about not meeting all the regulations. This is free training that can be done on a credit union’s site, on their time, with no financial outlay,” said Allison Griffin, one of the individuals responsible for producing the BSA video. The video will be made available to all TCUL members as their dues are paid. The production will be released later in the year in VHS and CD formats. -

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