LAS VEGAS (10/30/14)--Records should be kept for every transaction at a credit union, but there are rules about which records must be kept, for how long and how they must be disposed of. Rusty Vellek, compliance officer for Transportation FCU, Washington, D.C., with $193 million in assets, went over those requirements at the Credit Union National Association Bank Secrecy Act (BSA) Conference Wednesday.
"Your credit union's operations will be a big factor in how you keep BSA records," Vellek told his credit union audience, adding that credit unions are known to use hard copies, microfilm, microfiche, optical storage and combination of those and other media.
Records that need to be retained include:
U.S. Treasury Department regulations state these records must be kept for five years, with certain stipulations. Mortgage insurance premium information must be kept for five years from the date the account is closed. ID verification information must be kept for five years from the date of verification.
"There are no specified requirements for keeping [Financial Crimes Enforcement Network] 314(a) forms, but keep them at least long enough to demonstrate compliance to examiners and auditors," Vellek said.
The National Credit Union Administration, the Federal Credit Union Act, and state and federal laws also contain requirements that must be consulted.
Similar regulations must be referred to when it comes time to dispose of these records, as well as considerations of information and privacy requirements from state and federal entities. The actual method of disposal depends on the medium on which the records are kept.
Vellek said it's also recommended that financial institutions keep a record of how and when the records were disposed of or discarded.
Wednesday was the final day of the BSA Conference, co-sponsored by CUNA and the National Association of State Credit Union Supervisors. The annual event draws hundreds of credit union representatives and offers a certification course and certificate for BSA compliance.