Monitoring Bank Secrecy Act Compliance

Forms and Documents

Document Name	Status
FINAL0108 Justification 2013.doc Supporting Statement A	2013-10-28

IC Document Collections

IC ID	Document Title	Status
32733	Monitoring Bank Secrecy Act Compliance	Modified

ICR Details

OMB Control No: 3133-0108	ICR Reference No: 201308-3133-006
Status: Historical Active	Previous ICR Reference No: 200610-3133-002
Agency/Subagency: NCUA	Agency Tracking No:
Title: Monitoring Bank Secrecy Act Compliance
Type of Information Collection: Reinstatement without change of a previously approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/17/2013
	Date Received in OIRA: 10/28/2013
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2016	36 Months From Approved
Responses	6,753	0	0
Time Burden (Hours)	108,048	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The collection is needed to allow NCUA to determine whether credit unions have established a program reasonably designed to assure and monitor their compliance with currency record keeping and reporting requirements established by Federal statute and Department of Treasury Regulation.

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Authorizing Statute(s): US Code: 31 USC 5311-5330 Name of Law: Bank Secrecy Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	78 FR 43233	07/19/2013
30-day Notice:	Federal Register Citation:	Citation Date:
	78 FR 53168	08/28/2013
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Monitoring Bank Secrecy Act Compliance

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	6,753	0	0	-1,942	0	8,695
Annual Time Burden (Hours)	108,048	0	0	81,963	0	26,085
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: There are fewer federally insured credit unions than there were when the last approval for a collection of information was made. Therefore, the number of respondents has been adjusted to reflect this decline. Credit unions continue to adjust their membership base, the products and services they offer and the geographical locations they service, thus increasing the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Risk to the credit unions. Advances in the technological aspects of mobile banking and electronic payments have also increased this risk. Due to the increased BSA/AML Risk to the credit unions, it is expected that the credit unions would revisit and revise their BSA/AML compliance programs accordingly to address these added risks. The amount of time it takes the credit unions to review and assess the existing program as well as any additional risk related to expanded products, services, membership, etc. has been revised to more accurately reflect the burden to the credit unions. It is noted that credit unions vary in size, complexity, and BSA risk, thus the 16 hours is an average estimate of the amount of the burden.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/28/2013

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