Structuring

Structuring is “the breaking up of transactions for the purpose of evading the Bank Secrecy Act reporting and recordkeeping requirements.”  See FinCen Ruling 2005-6 – Suspicious Activity Reporting (Structuring).    A member might try to deposit funds over a period of days or go to multiple branches of the credit union to try to hide the…

You’ve Got Mail (and Title)

The following is an article reprinted with permission from The WWR Letter:  You’ve Got Mail (and Title) By: Matthew Young, Esquire  In most states, repair garages and places of storage have certain remedies where a vehicle remains unclaimed by its owner for a certain period of time. In Ohio, this period of time is fifteen (15) days or…

The Trials and Tribulations of a Credit Union Director. Part II.

Imagine having a job that involves setting the course of a financial institution, supervising a manager, and understanding and approving financial reports, policies and other business.  Add in the responsibilities of developing an understanding of regulatory compliance as well as vendor contracts and it’s almost overwhelming.  While meetings for this job are generally only monthly,…

Be careful with Representative Payee accounts where there is no guardian.

Most credit unions work with Representative Payees on Social Security or Social Security Income fairly frequently. In the case of a minor or a person who is legally incompetent, a Representative Payee is required. State law typically creates a mechanism for guardians to be appointed for incompetents. However, Social Security will sometimes appoint a Representative Payee for someone…