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Credit Union Fraud by htv91369

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									FRAUD POLICY STATEMENT


Alternatives Federal Credit Union considers any form of fraud, dishonesty or manipulation on the
part of its officials (all board members including committee members) or employees as totally
unacceptable conduct. Fraud includes any act, omission, or concealment that involves a breach of
duty, that involves a breach of trust, or involves a breach of confidence. Dishonesty infers a
disposition to fraud, untrustworthiness, or lack of integrity. Acts which are considered to be either
fraudulent or dishonest include, but are not limited to:

   1) Manipulation of credit union or member loan accounts, documents, computer records, share
       accounts, share draft accounts, or other depository accounts.
   2) Theft of any kind, including misappropriation of funds from members’ accounts,
       overpayment of dividends, creating fictitious accounts (either loan or share), or any other
       unauthorized misapplication of funds.
   3) Check kiting or other unauthorized overdraft and deposit methods and practices.
   4) Forgeries or unauthorized alterations of any documents whatsoever.
   5) Unauthorized or unapproved salary advances, compensatory time off, leave advances, or
       overtime reimbursements, including unauthorized or unapproved use of time sheets.
   6) Software piracy or unauthorized or unapproved use of computer time or equipment.
   7) Intentional violation of credit union policies, rules, internal controls, regulations or
       procedures.
   8) Giving out passwords/authorizations/combinations and/or keys to anyone not authorized to
       be in possession of such things.
   9) Intentionally failing to secure collateral, to properly record a security interest in collateral or
       pledging a member’s depository accounts or other property as collateral without that
       member’s permission.
   10) Obtaining employment on the basis of false or misleading information.
   11) Initiating any activity on a member’s account without prior approval of the member or of
       management.
   12) Initiating any activity on an employee’s own personal account or employee’s family
       account (including domestic partners).
   13) Granting or requesting preferential treatment for anyone.
   14) Disclosing confidential credit union information to any one not entitled to or authorized to
       have the information.
   15) No credit union official or employee shall accept any gift, favor, or hospitality offered or
       tendered where the gift, favor or hospitality possesses any of the following characteristics:
           a. In substance or form that an impartial observer would considerate to be an improper
                incentive.
           b. It places the official or employee under an actual or implied obligation.
           c. It has a value equivalent to or greater than $25.
           d. It is in the form of cash of cash equivalents.


       I have read the above Fraud Policy Statement and understand that this statement is required
       of all officials and employees of Alternatives Federal Credit Union. I understand that the
       Board of Directors and management will not tolerate fraudulent or dishonest acts of any
       kind and I am not to engage in acts of fraud, dishonesty or manipulation while servings as a
       credit union official or employee of Alternatives Federal Credit Union. I further understand
that engaging in such acts will be grounds for disciplinary action, up to and including
immediate dismissal and termination of my employment with Alternatives Federal Credit
Union. I have received a copy of this statement and understand that the original signed copy
will be retained by the credit union in my personnel file.

__________________________________________
___________
Board Member, Committee Member, or Employee                                       Date
            Signature


__________________________________________
      ____________
Witness                                                                           Date
Alternatives Federal Credit Union
Fraud Policy Statement

General Policy Statement - Alternatives does not tolerate fraud by its officials or
employees.

Unacceptable Acts: are listed in the employee statement above.

Deterrence:
       a) Internal Controls. The Board of Directors is responsible to institute internal
          controls to deter fraud. The Supervisory Committee periodically examines the
          internal control for sufficiency and effectiveness.
       b) Employee Statement. All Credit Union Officials and staff will sign a statement
          defining acts considered fraudulent and acknowledging that fraud of any type
          will not be tolerated.

Investigation:
        a) Confidentiality. Suspected fraud should be kept strictly confidential. The
            suspicion should only be discussed with individuals responsible for investigating
            it.
        b) Inform the CEO immediately. If you feel the CEO was involved, inform HR.
        c) Investigation by Supervisory Committee. Suspected fraud should be reported to
            the Supervisory Committee, who should immediately investigate. To the extent
            necessary, the Committee may involve additional persons to assist it, such as:
                a. Credit Union Management b. External auditors c. NCUA

Response:
       a) Initial Response: Remove Opportunity for additional fraud. When the Credit
           Union learns that an employee or official has committed fraud, the Credit Union
           will immediately remove any opportunity for commission of additional fraud.
           This initial response may require that the employee or official be transferred,
           relieved of their duties or suspended.
       b) Final Response: Termination or Suspension. The Credit Union’s final response
           may be termination or suspension. In determining the appropriate response,
           factors to consider include: nature of offense, dollar amount involved, effect on
           bond coverage, employment policy and state and federal employment laws and
           regulations.
       c)
Notification:
       a) Law enforcement of incidents involving theft, embezzlement, forgery or other
           criminal offence.
       b) NCUA of any crime or suspected crime (NCUA form #2362, Suspicious
           Activity Report).
       c) Fidelity Bond insurance company.

								
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