North Dade Community Development Federal CU
On September 6, 2013, the National Credit Union Administration issued a Consent Cease and Desist Order to North Dade Community Development Federal Credit Union, Miami Gardens, Florida (CU).
The CU is a federally chartered credit union with its only office located in Miami Gardens, Florida. According its last call report, it has approximately $5.8 million in total assets and 780 members. On September 6, 2013, the NCUA and the CU entered into a consent Cease and Desist Order under which the CU has been directed to:
- within 30 days, stop transacting any business activity for all MSBs not located within the CU's geographic Field of Membership (FOM) limits
- immediately start verifying that all persons or entities are within the FOM and eligible for membership in the CU before providing them membership or membership services
- within 30 days, suspend transacting business for all member MSBs until the CU develops and implements an adequate BSA/AML/OFAC program
- engage an individual or firm of BSA/AML/OFAC specialists acceptable to the NCUA Regional Director as a consultant to assist in correcting, at a minimum, the BSA/AML/OFAC program deficiencies identified in the Order
- within 30 days, hire or designate a BSA Compliance Officer with the knowledge, experience, delegated authority and resources to ensure compliance with 12 CFR Part 748 and other applicable BSA/AML/OFAC laws and regulations
- within 60 days, complete a comprehensive BSA/AML/OFAC risk assessment with the assistant of the consultant, and establish policy on the frequency of reviews and updates of the assessment. As part of the assessment, a list of high risk members must be established and maintained.
- within 60 days, revise and document board approval of all policies relating to BSA, AML and OFAC (minimum criteria for such policies included in Order)
- within 60 days, ensure that all staff and officials are adequately trained on the requirements of 12 CFR Part 748 and other applicable BSA/AML/OFAC laws and regulations, providing the NCUA Regional Director with copies of training materials and documentation of completion
- within 90 days, develop a system of internal controls to ensure ongoing compliance with Part 748 and all applicable BSA/AML/OFAC laws and regulations
- conduct BSA/AML/OFAC compliance program testing
- ensure that BSA/AML/OFAC testing is complete and results are reported to the CU's board of directors