NVCU PoliciesThe legal stuff...

Nishna Valley Credit Union's Privacy Policy Statement

A Private Note to Our Members:

Nishna Valley Credit Union is committed to making available financial products and services that will enable you to meet your financial needs and reach your financial goals. Protecting personal information and using it in a manner consistent with your expectations is a high priority for everyone associated with our credit union. As a member of our credit union, you also have a responsibility to safeguard your financial information. To ensure that you can rely upon the quality of products and services we make available, our credit union stands behind the following privacy policy:

Nishna Valley Credit Union will collect only the personal information that is necessary to conduct our business. That means just what is necessary to provide competitive financial products and services and nothing more.

Nishna Valley Credit Union will protect your personal information. Nishna Valley Credit Union will maintain strong security controls to ensure that member information in our files and computers is protected. Where appropriate, we will use security-coding techniques to protect against unauthorized access to personal records, ensure accuracy and integrity of communications and transactions, and protect member confidentiality.

You will always have access to your information. As a member of Nishna Valley Credit Union, you will always have the opportunity to review your information and make necessary changes to ensure that our records are complete and accurate.

Nishna Valley Credit Union will only share information when absolutely necessary. We will only share information to administer the products and services we provide, when required to do so by the government, or when we partner with other businesses to offer a broader array of products and services.

Nishna Valley credit union will partner only with businesses that follow strict confidentiality requirements. The businesses we select will offer products designed to enhance our members' economic well being. Under no circumstances will we authorize these firms to charge your account without express consent, and we will not sell member information to telemarketing firms.

Nishna Valley Credit Union will offer you a choice in how your information is used. Any member of the credit union may elect to keep information from being shared with our business partners. We will inform you on how to exercise your choice, and we will take all reasonable steps to make sure your requests are followed. At least once a year, we will remind all members of your right to choose.

Also, because the Board and Staff live in the same world as you and we know how agitating telemarketing can be. None of our business partners are authorized to contact you by phone, unless you request them to.

If you receive an unsolicited phone call from one of our business partners, please let the credit union know.

NISHNA VALLEY CREDIT UNION BANK SECRECY ACT POLICY

Incorporating the USA PATRIOT Act requirements

Introduction

It is the purpose of these policies, in conjunction with related credit union procedures, to ensure that NISHNA VALLEY Credit Union operates in compliance with the federal Bank Secrecy Act (BSA), the Money Laundering Control Act (MLCA) and the USA PATRIOT Act's customer identification program and information sharing requirements, and their implementing regulations.

Designation of Bank Secrecy Act Compliance Officer

NISHNA VALLEY Credit Union will designate a BSA Compliance Officer who will be responsible for ensuring that:

  • BSA reports are filed in a timely manner
  • Account-opening procedures comply with CIP requirements
  • Appropriate staff training is provided
  • Annual BSA auditing is performed as required
  • Records are retained as required by the BSA

Member and Non-Member Customer Identification

This policy and its implementing procedures are designed to comply with the Member and Customer Identification Program (CIP) requirements for identifying individuals and entities establishing accounts.

NISHNA VALLEY Credit Union's CIP program consists of this board-approved policy as well as procedures established by management that at a minimum includes:

  • Verifying the identity of any member or customer seeking to open an account;
  • Maintaining records of the information used to verify identity, using either unexpired government-issued documents or non-documentary verification; and
  • Determining whether the member or customer appears on any government list provided to the credit union by federal agencies.

In formulating procedures that factor in the level of risk the credit union faces in opening an account for an individual or business, management will take into consideration the types of accounts the credit union offers, methods of establishing accounts, and verification procedures. Procedures will identify what documentary and non-documentary evidence of identity will be acceptable for compliance purposes. New members and customers establishing any type of account on or after October 1, 2003 will be subject to the CIP procedures.

Accounts include all formal account relationships, whether established as share, share draft, certificate, or other savings account, as well as loan account relationships. The term customer includes non-member joint owners, non-member co-borrowers or any other individual or entity (business, corporation, trust, partnership) establishing a formal account relationship with NISHNA VALLEY Credit Union who will not be a member.

NISHNA VALLEY Credit Union will require that every new member or customer provide a name, date of birth, address and identification number prior to opening an account. NISHNA VALLEY Credit Union will take reasonable steps to verify this information through appropriate documentary or non-documentary verification methods as specified in this credit union's CIP procedures.

NISHNA VALLEY Credit Union's CIP program will require additional verification for individuals whose true identity cannot be verified using the standard verification methods. NISHNA VALLEY Credit Union will not open an account if it cannot verify a member's identity.

Before opening an account, a new member or customer will be advised of the credit union's CIP program, as explained in the implementing procedures.

NISHNA VALLEY Credit Union believes it has a reasonable basis to assume that members and customers of record of the credit union as of October 1, 2003 are known to the credit union. If events occur that raise questions of whether the credit union knows the true identity of a person, the credit union will seek to verify the person's identity, as set forth in the implementing procedures.

Customer Identification Program

NISHNA VALLEY Credit Union will make and maintain a record of all required information it receives from its members or customers when complying with its CIP procedures. The records will include a description of any document the credit union relied upon for compliance purposes.

NISHNA VALLEY Credit Union will retain the information it receives from its members for five years after the date the account is closed. NISHNA VALLEY Credit Union will keep the information it records when verifying a member's identity for five years after the record is made, including a description of any document that was relied on to verify its member's identity; any identification number in the document; the place the document was issued; and the date of issuance and expiration date, if any. NISHNA VALLEY Credit Union will also keep a description of the methods and the results of any non-documentary measures undertaken to verify the identity of the member and a description of the resolution of any substantive discrepancy discovered when verifying the identifying information obtained.

Monitoring Government Lists

NISHNA VALLEY Credit Union will maintain procedures for determining whether any party to any transaction processed by the credit union appears on the Office of Foreign Assets Control's Specially Designated Nationals and Blocked Persons List. The credit union will block the account or reject the transaction of any individual appearing on that list in accordance with instructions from OFAC.

NISHNA VALLEY Credit Union will respond in a timely manner to any request for information submitted by the Financial Crimes Enforcement Network (FinCEN) in order to further law enforcement agencies' investigation of suspected terrorists or money launderers.

When published, NISHNA VALLEY Credit Union will maintain procedures for determining whether a member/customer appears on any list of known or suspected terrorists or terrorist organizations issued by any federal agency and designated as a CIP Section 326 List by the Treasury or other agencies.

Staff Training

NISHNA VALLEY Credit Union has developed and implemented a training program, which ensures that all employees are trained in procedures relating to the BSA and this policy.

The BSA Compliance Officer will be responsible for ensuring that all appropriate personnel are aware of their responsibilities in conjunction with administering the BSA program.

BSA Audit

NISHNA VALLEY Credit Union shall conduct an internal audit to verify its system of internal controls and test for ongoing compliance with the BSA procedures. Copies of the audit will be signed, dated and maintained for review by the NCUA examiners, with copies sent to Management, the BSA Compliance Officer, and the Supervisory Committee.

Nishna Valley Credit Union Customer Identification Policy

NISHNA VALLEY Credit Union is adopting this policy to comply with the requirements of the USA PATRIOT Act and its implementing regulations to establish the identity of individuals and entities opening accounts at the credit union.

NISHNA VALLEY Credit Union's Member and Customer Identification Program (CIP) will consist of this board-approved policy as well as procedures established by management that at a minimum will include:

  • Verifying the identity of any member or customer seeking to open an account;
  • Maintaining records of the information used to verify identity, using either unexpired government-issued documents or non-documentary verification methods; and
  • Determining whether the customer appears on any government list provided to the credit union by federal agencies, when these federal lists are issued.

In formulating and maintaining appropriate procedures, management will take into consideration the types of accounts offered, the method of establishing accounts, and the credit union's field of membership, to determine what level of risk the credit union feels it has in opening accounts. Procedures will establish what documents and non-documentary information are to be relied upon to verify identity.

For purposes of the CIP, accounts include all formal account relationships established, whether established as share, share draft, certificate, or other savings account, as well as loan account relationships. New members and customers establishing any type of account on or after October 1, 2003 will be subject to the CIP procedures. The term customer includes non-member joint owners, non-member co-borrowers or any other individual or entity (business, corporation, trust, partnership) establishing a formal account relationship with NISHNA VALLEY Credit Union who will not be a member.

NISHNA VALLEY Credit Union will require that every new member or customer provide a name, date of birth, address, and identification number prior to opening any account. NISHNA VALLEY Credit Union will maintain this information for five years after the account is closed. NISHNA VALLEY Credit Union will take reasonable steps to verify this information through documentary or non-documentary verification methods as required by the Treasury Department's CIP regulations. The verification methods NISHNA VALLEY Credit Union will accept are specified in NISHNA VALLEY Credit Union's CIP procedures, and the description of documents reviewed and the verification method used will be maintained for five years after the description is recorded.

NISHNA VALLEY Credit Union's CIP program will require additional verification for individuals whose true identity cannot be verified using the standard verification methods. NISHNA VALLEY Credit Union will not open an account if it cannot verify a member's identity.

The Bank Secrecy Act officer is responsible for maintaining ongoing compliance with the PATRIOT Act requirements and its implementing regulation. Appropriate staff will be adequately trained on BSA and CIP requirements.

An annual internal audit of CIP compliance will be conducted.

Before opening an account, potential members and new customers will be advised of the credit union's CIP program through the appropriate notice as specified in the implementing procedures.

NISHNA VALLEY Credit Union believes that it has a reasonable basis to assume that members and customers of record as of October 1, 2003 are known to the credit union. If events occur that raise questions as to whether the credit union knows the true identity of a person, the credit union will seek to verify the person's identity, as called for in the CIP procedures.

NISHNA VALLEY CREDIT UNION CIP PROCEDURES FORMAT

PURPOSE OF THE MEMBER AND CUSTOMER IDENTIFICATION PROGRAM (CIP)

This program is designed to assure Nishna Valley Credit Union's compliance with the USA PATRIOT Act and the implementing regulatory requirements of the U.S. Treasury Department and the National Credit Union Administration to assist in preventing and tracking money laundering and terrorism financing activities. These procedures implement the policy adopted by Nishna Valley Credit Union's board of directors. Nishna Valley Credit Union will take reasonable and practical steps to verify the identity of people who open accounts with the credit union.

COVERAGE

These CIP procedures will apply after October 1, 2003 to anyone establishing a formal relationship with Nishna Valley Credit Union to provide services, or engage in other financial transactions that include share, share draft, certificate, or other accounts, as well as loan account relationships.

The term customer as used in this program refers to anyone establishing an account relationship with Nishna Valley Credit Union, including members, non-member joint owners, non-member co-borrowers or any other individual or entity (business, corporation, trust, partnership) establishing a formal account relationship with Nishna Valley Credit Union. The term customer also refers to the individual who opens an account for a minor lacking legal capacity or for an entity that is not a legal person, such as a high school class, bowling league, etc.

If events occur that raise questions about the true identity of an existing member or customer, Nishna Valley Credit Union will follow these procedures to verify that person's identity.

COLLECTION OF INFORMATION FROM INDIVIDUALS

Information required: Nishna Valley Credit Union requires the following information be provided by each individual member or customer before opening an account with the credit union:

  • Name
  • Residential or business street address, plus a mailing address if different than the residential or business street address, APO or FPO box number for members of the military; residential or business street address of relative or another contact individual.
  • Date of birth
  • Identification number, which will be a Social Security number for U.S. citizens. For non-U.S. persons, the identification number will be a taxpayer identification number (Social Security number or individual taxpayer identification number); passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
  • State issued driver's license, if applicable.

If a TIN has been applied for: Nishna Valley Credit union will not open an account for an individual awaiting a Social Security number or individual taxpayer identification number (ITIN). Once the Social Security number or ITIN has been received, an account will then be opened.

VERIFICATION OF THE IDENTITY OF INDIVIDUALS

For accounts opened in person: Nishna Valley Credit Union will verify the identity of a new member or a customer appearing at the credit union by examining the following unexpired documents that look authentic: Social Security Card, state issued driver's license, state issued identification card, US or foreign passport, or Military ID. These items will be photo copied and kept for a period of no less than 5 years after the account is closed. If the document presented for purposes of identification is not one the staff who opens accounts is familiar with, another staff member will be called in to assist. If no staff member is familiar with the document, the account will not be opened until proper identification can be given.

For accounts opened with the person not present at the credit union: Nishna Valley Credit Union will not open accounts without the account holder present to verify identity.

Accounts opened prior to verification: Nishna Valley Credit Union does not open any accounts before the verification procedure is completed.

Discrepancies with information provided: Nishna Valley Credit Union will seek to resolve any substantive discrepancies discovered when verifying the identifying information obtained from a person, and will record the description and results of any measures used to resolve those discrepancies.

BUSINESS ACCOUNTS

Information collected on businesses: The following information is collected from a business (sole proprietorship, partnership, or corporation and other non-natural person entity, such as an association or trust), opening its first account at Nishna Valley Credit Union:

  • Name
  • Address, office locations, principal place of business, local office, etc.
  • Employer Identification Number (EIN)
  • Name, address, and social security number of the person opening the account on the business's behalf.

If an EIN has been applied for: ABC Credit union will not open the account if the business is awaiting the issuance of its EIN.

Verification of the identity of the business: Before opening an account for a business Nishna Valley Credit Union will verify the existence of the business by requesting a copy of the articles of incorporation, a government issued business license, federal tax ID number, or a partnership agreement.

Verification of individual owners and signatories: Nishna Valley Credit Union will always obtain information about the person opening the account or individuals with authority or control over the new account of the business. Verification of individuals connected with the business will occur when Nishna Valley Credit Union cannot otherwise establish a reasonable belief that it knows the true identity of the business.

Accounts opened prior to verification: Nishna Valley Credit Union does not open any accounts before the verification procedure is completed.

Discrepancies with information provided and staff concerns: Nishna Valley Credit Union will seek to resolve any substantive discrepancies discovered when verifying the identifying information obtained from a business, and will record the description and results of any measures used to resolve those discrepancies. If at any time staff opening accounts have reason to believe that the identity of the business is in question, they are to bring this concern to the attention of management for consideration of action not to open the account or to close the account.

FILING SUSPICIOUS ACTIVITY REPORTS

Nishna Valley Credit Union complies with mandatory requirements in law and regulation to file suspicious activity reports (SARs). Staff who open accounts are required to bring to the attention of management any concerns about suspicious activities of people or businesses seeking to join or open an account at the credit union. Nishna Valley Credit Union will consider filing an SAR when documents appear fraudulent, or fraudulent activity is suspected.

RECORD RETENTION

Information collected: The information required from the individual and business accountholders (name, date of birth, address, identification number and any other information collected under these procedures) will be retained for five years after the account is closed. This information will be kept in the member's file and can be retrieved if necessary for the federal government.

Verification descriptions: Records on the descriptions of any document (including type of documents, identification number, place of issuance and, if any, date of issuance and expiration), descriptions of non-documentary methods used, and descriptions of any resolution of substantive discrepancies found when verifying an identity will be retained for five years after the account is opened. This information is also kept in the member's file.

CHECKING GOVERNMENT LISTS

[Reserved: yet to be announced by Treasury]

[Procedures will need to be developed once the Treasury Department issues any information on any designated CIP lists, which are in addition to the credit union's current responsibilities for checking names against the OFAC lists and the FinCEN requests.]

CIP NOTICE

Nishna Valley Credit Union will notify new member and customers about the credit union's CIP policy by posting it the lobby and on our website. Information is also available to the members verbally or in writing as a handout.

ANNUAL AUDIT

Nishna Valley Credit Union will have an annual audit conducted internally to determine whether the requirements of the customer identification program are being met.

TRAINING

Nishna Valley Credit Union's service staff will be required to participate in regular Bank Secrecy Act training, including customer identification program requirements and procedures. Evidence of participation will be retained for audit purposes.