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Compliance Take a CTR quiz
WASHINGTON (12/118/08)—The Bank Secrecy Act, also known as BSA or the bane of compliance officers’ existence, lays out pretty precise rules about when a credit union may designate a Phase II exemption for a member business account. The Credit Union National Association’s December Compliance Challenge features a number of BSA-related questions that reflect the changes brought about by the new currency transaction report (CTR) exemption rules issued by the Financial Crimes Enforcement Network (FinCEN) this month. For instance, what can you do if your federal credit union has a business account that engages in a number of frequent transactions throughout the year that trigger currency transaction report (CTR) filings and your member service representative would like to know if the business account would qualify for a Phase II exemption for non-listed businesses? Let’s say the business account generates a number of currency transaction report (CTR) filings and your member service representative would like to know if the business account would qualify for a Phase II exemption for non-listed businesses. Take this multiple choice quiz: According to the BSA (31 CFR 103.22), in order to qualify for a Phase II exemption from CTR filing, a business would must maintain its account with the credit union for a minimum number of months and have engaged in a minimum number of transactions per year. Which one of the following is correct?
* A. A business would have to maintain its account for at least 12 months and have at least 8 transactions per year to qualify. * B. A business would have to maintain its account for at least 6 months and have at least 20 transactions per year to qualify. * C. A business would have to maintain its account for at least 2 months and have at least 5 transactions per year to qualify. Or, * D. A business would have to maintain its account for at least 8 months and have at least 8 transactions per year to qualify.
Did you know the correct answer is “C”—or did you just guess right? Use the resource link below to find out why “C" is correct and to read more compliance jewels.


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