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Regarding the Dec. 12, 2007 article entitled “CUNA BSA Task Force Meets with NCUA Board Member Hyland, Head of FinCEN,” I must respectfully disagree with the assumption that Bank Secrecy Act compliance absorbs a large share of credit unions’ resources. Depending on the reliability of the member profiles and the aptitude of the staff, a credit union should be able to perform all necessary BSA requirements when employing the services of a BSA specialist. BSA specialists serve multiple institutions by acting as an independent arm of the CEO and Board of Directors who is an “as-needed resource” performing only those services necessary for compliance. The BSA specialist begins by assessing the institution’s current program to identify any area lacking full compliance. The specialist then develops enhancements to current procedures to resolve any identified weakness and most importantly performs post-assessment reviews to assure full implementation of the enhanced procedures. For most institutions under $750 million the annual cost should not exceed $10,000 per year plus travel expenses. The larger institutions should consider employing a full-time experienced BSA officer if they encounter more than 100 Currency Transaction Report filings annually.

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