InfoSight Model Policies Update Posted by AVCU on 12:35 PM

InfoSight is the Association’s online compliance manual for member credit unions. It has over 50 model policies available for download to modify and fit your credit union. InfoSight is password protected for member and requires a small annual subscription. Send email to jjc@vcul.org if you aren’t subscribed or need log on information. Here’s a list of some of the recently updated policies:

2110 – Bank Secrecy Act: Added information on Money Services Businesses; added additional information and modified verbiage in the CTR section, including added information on Exemptions (final rule from FinCEN’s bulletin from December, 2008); added information to Information Sharing, including sharing information with the FBI.

2145 – OFAC: Clarified information related to the Risk Assessment – Initial Review; added information to the “Update of OFAC Information” section, including which parties will be checked against the OFAC list, and which transactions are subject to OFAC regulations; and added a section on International ACH regulations.

2211 – Business Accounts: Added information relating to when dividends and interest are credited for Share/Saving Accounts, Money Markets, and Share Draft/Checking Accounts; and additional minor formatting and verbiage changes were made.

2220 – E-Commerce: Minor changes. Key Field was added to the “Services” section [1(B)(vi)(12)] to allow the credit union to customize other e-commerce activities and services they are providing; and additional minor verbiage changes were made (most added cross references to policies numbers for other policies that were mentioned).

4120 – Information Security: Added information to “Controls” section on guarding the display of information on computer screens; removed information related to outsourcing of services (and cross referenced the Vendor Due Diligence policy); and additional minor verbiage changes were made.

7330 – Residential Real Estate Loans: Added information on use of third party brokers and correspondents; added information on higher priced mortgage loans; removed information on RESPA disclosures (and cross reference the Truth-in-Lending for Closed-End Credit policy); added information on servicing; revised information on modifications to loss mitigation strategies.