True or False: A small credit union can have its BSA officer solely determine when a CTR is necessary?

True or False: A small credit union can have its BSA officer solely determine when a CTR is necessary?

• A. True
• B. False
• C. True, with Board approval
• D. False, but only for larger transactions

Answer: (B)

The answer is false because a small credit union, like any other financial institution, is required to have a clear process for determining when to file a Currency Transaction Report (CTR). While the BSA officer plays a crucial role in compliance and may identify when a CTR is needed, the responsibility cannot rest solely on that individual. Regulatory guidelines necessitate collaboration and oversight, including input from appropriate governance structures within the credit union, such as the board of directors or compliance committee. This ensures a checks and balances approach, vital for sound compliance practices, especially in a BSA context where accurate reporting is critical for preventing money laundering and other financial crimes. Therefore, it is not sufficient for just one individual, even if they are a designated officer, to make that determination independently.

The answer is false because a small credit union, like any other financial institution, is required to have a clear process for determining when to file a Currency Transaction Report (CTR). While the BSA officer plays a crucial role in compliance and may identify when a CTR is needed, the responsibility cannot rest solely on that individual. Regulatory guidelines necessitate collaboration and oversight, including input from appropriate governance structures within the credit union, such as the board of directors or compliance committee. This ensures a checks and balances approach, vital for sound compliance practices, especially in a BSA context where accurate reporting is critical for preventing money laundering and other financial crimes. Therefore, it is not sufficient for just one individual, even if they are a designated officer, to make that determination independently.