What’s Inside
The FFIEC and CFPB are urging credit unions to identify and monitor high-risk activity amongst their member base. The transaction pattern option within the Abnormal Activity Monitoring CU*BASE tool was designed to assist credit unions with meeting that requirement. The patterns need to be configured specific to your credit union, because every credit union has a different membership composition. A well-tuned configuration is vital for achieving an efficient and effective abnormal activity identification and review process. It is also imperative to have a method for ensuring the integrity of the data being reviewed, that is, something to record the before-and-after of what a configuration was prior to it being changed. A documented basis for why a change was made is equally important.
When making adjustments, an important question to keep in mind is: “By changing this pattern, will previously flagged high-risk accounts no longer be identified?”
The booklet covers the following process.
- Making Adjustments to the Default Configurations
- Recording Configuration Changes
- Reviewing Accounts to Determine False Positive Rate
- Recording False Positive Rates
- Recording Configuration Changes
Also included: Templates for making it all easy!
Who Should Read This Booklet?
This booklet was written for the BSA compliance practitioner, from a practitioner’s perspective. Specifically, it is useful for the BSA Compliance Officer or designated personnel as a guide for adjusting transaction pattern configurations. Instead of identifying and reviewing accounts with normal activity, dial in your patterns to flag what is truly unusual.
