Help Members Switch to Direct Deposit

Change will save taxpayers $120 million annually.

March 1, 2012

The Treasury Department requires all federal benefit check recipients to switch to an electronic payment method by March 1, 2013. With just one year left until the deadline, credit unions can help members make the switch to direct deposit now.

This change saves taxpayers $120 million annually, Treasury reports. Credit unions can use their own direct deposit enrollment methods, have members visit the Treasury Department’s Go Direct® campaign website at, or call 800-333-1795.

Since 2005, more than 500 credit union partners have helped the Go Direct campaign switch more than eight million senior citizens, people with disabilities, and others from paper checks to direct deposit.

Three tips to make the transition easier for you and your members:

  1. Train tellers and front-line staff. When tellers talk, people listen. Coach tellers to talk to your members who are cashing or depositing federal benefit checks about the change and then sign them up for direct deposit on the spot. 
  2. Display materials. Free Go Direct campaign materials such as fliers and teller tents are available to display in lobbies or hand out at events. 
  3. Push out information. Newsletter copy, Web banners, and other materials also are available to include in newsletters, websites, social media channels, and presentations.

For more information or to download or order free materials, visit or call 952-346-6055.

Talking’ ATM Standards Take Effect March 15

The 2010 Americans with Disabilities Act (ADA) Standards for Accessible Design go into effect on March 15, 2012. Section 707 of the standards requires, among other things, that ATMs be speech-enabled for the visually impaired.

The new standards include a safe harbor for “elements” built to comply with the original 1991 ADA accessibility standards. But the safe harbor doesn’t apply to “auxiliary aids and services,” such as communication-related elements of ATMs. In any case, the 1991 ADA standards require ATM instructions and all information be made “accessible to and independently usable by persons with vision impairments.” So practically speaking, ATMs must be speech-enabled to meet either the 1991 standard for independent usage, or the 2010 standard specifically requiring voice guidance.

ATMs not currently in compliance with the 1991 standards must be modified to comply with either the 1991 or 2010 standards by March 15, 2012. Consult with your ATM service provider to determine exactly what changes your ATMs require.

More information is available at

NLRB Delays Notice Deadline

Posting the National Labor Relations Board’s (NLRB) employee rights notice will now be required by April 30, 2012. The deadline was moved from Jan. 31, 2012.
This fulfills the NLRB regulations requiring most private-sector employers (including credit unions) to notify employees of their rights under the National Labor Relations Act.

Employers must post the notice in a conspicuous place, where they post other notifications of workplace rights and employer rules and policies. Employers also should publish a link to the notice on an internal or external website if they post other personnel policies or workplace notices there.

The notice is similar to the one the Labor Department requires for federal contractors. Credit unions already complying with the federal-contractor posting requirement will satisfy the NLRB requirement.

Copies of the NLRB notice are available at and from the agency’s regional offices.

Next: FinCEN Extends Deadline for Adopting New CTRs, SARs

FinCEN Extends Deadline for Adopting New CTRs, SARs

Financial Crimes Enforcement Network (FinCEN) has extended the deadline for financial institutions to use the agency’s new Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR) to March 31, 2013.

FinCEN extended the deadline partly in response to industry concern about having sufficient time to transition to the new reports and to make necessary changes to internal processes and/or information technology systems. FinCEN had proposed financial institutions implement the new reports by June 30, 2012, the same date proposed for ending the paper-filing option for FinCEN forms. FinCEN expects this extended time frame for incorporating the new CTR and SAR to ease the industry’s transition to these new reports.


FAQs on Interest-Rate Risk Management

The Federal Financial Institutions Examination Council (FFIEC) agencies released answers to frequently asked questions (FAQs) about the January 2010 advisory on interest-rate risk management.

The FAQs respond to common questions critical to sound interest-rate risk management, including appropriate measurement and reporting, robust and meaningful stress testing, assumption development reflecting the institution’s experience, and comprehensive model validation.

The FAQs also provide examples of risk management expectations for financial institutions of various interest-rate risk profiles, including how to adjust processes as risks change. Find more information at or


Q Is the credit union required to file a Suspicious Activity Report (SAR) each time it files a blocking report with the Office of Foreign Assets Control (OFAC)

A No. Blocking reports filed with OFAC fulfill the Bank Secrecy Act’s requirement to file SARs for such transactions. But there still may be instances where the credit union will have to file reports with both the Financial Crimes Enforcement Network (FinCEN) and OFAC. For example, credit unions are required to file a SAR in addition to the OFAC report if a transaction triggers BSA reporting rules for reasons other than a match on OFAC’s list (e.g., suspected money laundering or identity theft), or if the credit union possesses information not included on the OFAC report that should be filed with FinCEN.

Q Is a credit union required to file both a CTR and a SAR for a suspicious transaction in excess of $10,000 in cash?

A Yes. The Bank Secrecy Act (BSA) requires all financial institutions to file currency transaction reports (CTR) whenever a currency transaction exceeds $10,000. If a currency transaction exceeds $10,000 and is suspicious, the credit union must file both a CTR and a SAR to report the suspicious or criminal aspects of the transaction. If a currency transaction equals or is below $10,000 and is suspicious, the institution should only file a SAR.

Visit CUNA’s compliance blog—“CompBlog”—at Email with questions or ideas for blog posts, and keep the conversation going with your peers on COBWEB, CUNA’s compliance listserv.