Abnormal Activity Monitoring Transaction Patterns: A Guide for Change Management and Data Governance


The Transaction Pattern option within the Abnormal Activity Monitoring CU*BASE tool was developed to arm credit unions with a means to identify anomalous account activity daily. This booklet describes the change management and data governance methodology developed by AuditLink for use by our credit union partners

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.

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