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Security Program
For
ABC CREDIT UNION
(ADDRESS)
Program Overview
This security program was developed to comply with the requirements of section 205(e) of the
Federal Credit Union Act (12 U.S.C. 1785 (e)) and Part 748 of Title 12 of the Code of Federal
Regulations promulgated by NCUA. The program establishes security procedures and specifies
devices to discourage robberies, burglaries, larcenies and embezzlement; to assist in
identification and prosecution of persons who commit such crimes; and to prevent the
destruction of vital records at this credit union’s main office and each branch office.
Approval by Board of Directors
The Board of Directors at its regular meeting on _______________ adopted this program, and it
was entered into the minutes of that meeting.
Program Administration
1. Initial development of a written security program and subsequent modification of such
security program as circumstances or revised federal regulations may require.
2. Implementation of security procedures and internal controls prescribed by the security
program.
3. Selection, testing, maintenance and operation of security devices prescribed by the security
program.
4. Protection of vital records at each credit union office.
5. Provision for the initial and periodic training of employees in their responsibilities under the
security program, and in proper employee conduct during and after a robbery, burglary or
larceny.
6. Monitoring the effectiveness of the security program at each credit union office and
conducting periodic security audits at each office.
7. Consultation with local law enforcement agencies to develop coordinated robbery and burglar
alarm response plans for each credit union office.
There will be an annual review by the Board of Directors on the implementation, administration
and effectiveness of the security program at each credit union office. The Board of Directors
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may, at its discretion, require any additional reports it deems necessary to fulfill its responsibility
for supervision of the administration of this security program.
Internal Controls
The Board of Directors has adopted organizational and operational procedures to safeguard its
assets, check the accuracy and reliability of its accounting data, promote operational efficiency,
and encourage adherence to the prescribed managerial policies of this credit union. Many of
these internal controls are designed to protect the credit union against crimes of embezzlement,
and are included by reference as a part of this security program.
Accounting Controls
The Board of Directors has adopted an accounting system in accordance with the Accounting
Manual for Federal Credit Unions and generally accepted accounting principles. The system
incorporates internal controls to provide reasonable assurance that:
1. Transactions are executed in accordance with management's general or specific authorization.
2. Transactions are documented and recorded promptly to permit accurate preparation of
financial statements and to maintain accountability for assets.
3. Access to assets is permitted only with management's authorization; and
4. The recorded accountability of assets is compared with the existing assets at reasonable
intervals and appropriate action is taken with respect to any differences.
Audit Policy
The Supervisory Committee shall oversee a continuous program of internal auditing for such
procedures as bank reconcilements, as well as an annual outside audit by a firm of independent
public accountants.
Control of Currency Levels
1. Maximum currency levels will be assigned to each office. It is the responsibility of [Title of
Person Responsible] to ensure that currency is maintained at or below the specified level.
2. If the office exceeds the maximum level, the [Title of Person Responsible] will immediately
arrange for the removal of excess currency by means of armored transport services or other
insured mode of transportation.
3. Random cash audits will be performed at each office at least once per month. If excess
currency is discovered, it will be reported to the [Title of Person Responsible].
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4. Maximum currency levels for tellers will be established by the [Title of Person Responsible]
and reviewed by the Teller Supervisor. The [Title of Person Responsible] is responsible for
assuring the specified level is not violated.
5. If a teller accumulates currency over the assigned amount, the excess will be transferred to a
locked vault, safe, or other secure place at the earliest possible time.
6. Random audits of teller currency levels will be made to ensure that each teller will be checked
at least once per month. Excess currency violations will be reported to the [Title of Person
Responsible].
Wire Transfer Procedures
The banking industry uses several electronic networks for funds transfer services, including (1)
the Fed Wire, (2) CHIPS, (3) Bank Wire, (4) SWIFT, (5) Telex, and (6) ACH. Our credit union
uses only two of these, Fed Wire and ACH. This paper is our statement of procedures and
internal controls for wire transfer activities.
Several different services are provided by the Fed Wire, including (1) transfers of funds, (2)
securities sales and purchases, (3) sales and purchases of cash, (4) reserve position inquiries, (5)
TT&L status reports, and (6) ACH debits and credits. This procedure statement only applies to
transfers of funds; as needed, the other four subjects are addressed elsewhere in the manuals.
Wire Transfer Control Policies And Procedures
To the extent possible, we avoid using the telephone as a funds transfer instrument. The
telephone does not create a sufficient audit trail, nor does it allow for signatures or written
records of transactions. When the telephone must be used, a callback procedure will be followed
whereby an employee of the credit union calls a previously agreed upon telephone number to
verify the identity of the caller. Telephone requests are then documented on a wire transfer
request form, with the caller's name written in the signature block, and credit union employee’s
initials being placed next to this name.
Test words are used to authenticate wire transfer messages. Test words consist of a series of
numbers signifying different types of information. Test words precede the wire transfer
message. A current list of test words is kept in the credit union under lock and key and is only
available to authorized wire transfer personnel. The person receiving the incoming request is not
the same person that verifies the test word; a dual control person does this. Tests words and
messages are tightly controlled.
Before honoring a request for a wire transfer, the wire transfer clerk will call the bookkeeping
department and verify that sufficient collected funds are on hand to cover the transfer. At the
same time, the bookkeeping department will be asked to place a hold on the account for the
amount of the wire transfer.
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No one person shall be responsible for the origination, testing, processing, and balancing of a
wire transfer. Instead, someone other than the wire transfer clerk does testing and the accounting
department does balancing. A credit union manager must initial any “adjustment” to a wire
transfer operation.
We control wire transfer equipment, codebooks, terminal facilities, etc., so that access is limited
to authorized personnel. The wire transfer equipment has locking devices that prevent their use
during other than normal credit union hours. Computer programming personnel are never
allowed in the transfer area, as wire transfer personnel are never allowed in the computer area.
Processing Outgoing Wire Transfers
Outgoing wire transfers represent an extremely significant fraud vulnerability to the credit union.
Consider the consequences of a $2,000,000 unauthorized wire transfer; within hours, the funds
will have been withdrawn from the receiving credit union and will have permanently
disappeared.
All outgoing wire transfers will be tightly controlled. The person authorizing the transfer will be
someone incapable of actually sending the message. All outgoing wire transfers will be
accompanied by completion of the following form:
Incoming Wire Transfers
Each incoming wire transfer will be recorded in a bound logbook. Each entry in the logbook will
contain the following information: (1) date, (2) time, (3) name of sending credit union, (4) dollar
amount, (5) member to be credited, (6) account to be credited, and (7) initials of the credit union
employee processing the transfer.
As soon as an incoming wire transfer is received, the message will be logged and the
debits/credits necessary to effect the transaction will be completed. A control person must initial
the debits and credits before the funds can be disbursed (or credited to one of our member's
accounts).
Security Policies and Procedures
General Safekeeping Policy
The [Title of Person Responsible] will be responsible for implementation of security procedures
at each credit union office to provide for the safekeeping of currency, negotiable securities,
similar valuables and vital records at all times. Management in other departments will be
responsible for safekeeping of vital records affecting their areas. All employees at each office
will be familiar with and follow the prescribed security procedures.
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Dual Controls and Segregation of Duties
It is the policy of [your credit union] that management assigns duties to employees and
departments so that no one person may dominate any transaction from inception to termination.
In addition to this formal segregation of duties, teams of at least two employees will exercise
dual control under the following circumstances:
1. When deposits from night depositories and ATMs are retrieved and posted;
2. During audits of vaults, safes, cash drawers, un-issued negotiable instruments and cash funds;
and
3. When verifying currency being shipped or received.
Key and Combination Control
1. A record of key holders will be maintained in a secure location within each office and a copy
of such record will be filed with the [Title of Person Responsible].
2. All excess keys will be kept in a locked box in a secured area.
3. Employees will return office keys when they are transferred or when their employment is
terminated. If a terminated employee fails to return keys for any reason or is otherwise suspect,
the [Title of Person Responsible] will have the locks changed on all exterior doors.
4. Dual control will be maintained over vault and safe at each credit union office. Knowledge of
combinations and possession of keys necessary to access the vault or safe will be split between
two employees so that no single employee is capable of accessing the vault alone. An appropriate
number of employees will be assigned at each office to ensure access when employees are
absent.
Personnel Policies
1. Prospective employees of the credit union will be screened for criminal history. This screening
will include asking appropriate questions on application forms and during interviews through
HRS.
2. All employees responsible for currency or negotiable securities must telephone their
supervisor to explain all absences from work.
3. If an absent employee fails to telephone and explain an absence, the employee's residence will
be called to determine the reason for the employee's absence.
4. If telephone verification cannot be made, the employee's cash will be counted immediately.
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5. All employees who are responsible for currency or negotiable securities are required to take at
least one straight week of vacation each year.
6. All employees are expected to adhere to acceptable business principles in matters of personal
conduct, and to exhibit a high degree of personal integrity at all times. Employees are required
to acknowledge and sign the Fraud Policy (sample policy statement is attached).
Safekeeping of Currency, Valuables and Vital Records
1. All currency, negotiable securities and other valuables will be stored in a locked, burglarresistant vault or safe during non-business hours.
2. Vital records at each office will be stored in a locked, fire-resistant vault, or record safe
container during non-business hours.
3. Vital records include:
• Cash journals and other reports of original entry;
• General ledger and supporting subsidiary ledgers, including members' individual share
and loan ledgers;
• Loan notes and supporting documents if the loss of such instruments would preclude the
credit union from collecting the outstanding balances of the loans:
• Securities, certificates, and other documents, which are evidence of investments, owned
by the credit union:
• Minutes of the Board of Directors, and other committee minutes, which represent the
historical actions of management; and,
• The credit union's charter, bylaws, and related amendments.
4. Blueprints of specification documents for credit union offices, vaults, and any other structures
in which currency or other valuables are stored or handled will be kept in a secure area at a
central location. The [Title of Person Responsible] will maintain a record of all such documents
and their storage location.
Security Devices
The [Title of Person Responsible] shall provide testing, selecting, operating, and maintaining the
following security devices at each credit union office:
1. A burglar-resistant vault or safe for protecting cash and other liquid assets, which provides, at
minimum, protection equivalent to __________ [UL approved Class I].
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2. Burglar-resistant safes or money chests for protecting cash deposited at night depositories and
automated teller machines, which provide, at minimum, protection equivalent to
_________________________ [UL TL-30].
3. A fire-resistant record safe or vault for protecting vital records which provides, at minimum,
protection equivalent to ______________________ [UL Class 350].
4. A lighting system for illuminating, during the hours of darkness, the area around the vault due
to the vault being visible from outside the credit union office. Additional security lighting is
listed as follows; lighting to illuminate the parking lot, the area surrounding the credit union
office, the outer lobby, ATM and night depository. The Emergency lighting has back-up power,
which is ___________________________.
5. A covertly actuated silent alarm system to be used in the event of an attempted or perpetrated
robbery. The system is monitored by the nearest responsible law enforcement agency.
6. A burglar alarm system comprised of perimeter alarms to detect attempted or perpetrated
intrusion into the credit union offices. Area alarms to detect unauthorized activity on the office
floor, and/or point alarms to detect attempted or perpetrated intrusion into vaults, safes, night
depositories and ATM's. The system will be monitored by
_____________________________________ [named security firm].
7. Tamper-resistant locks on all exterior doors and windows that may be opened.
8. Surveillance cameras that record activities at the credit union offices and at remote ATM's and
night depository facilities.
9. Bullet-resistant glass enclosures around drive-up teller windows.
10. A prominently displayed decal, which states that the Federal Bureau of Investigation has
jurisdiction to investigate felonies committed against the credit union.
11. Such other devices as the [Title of Person Responsible] may determine to be appropriate,
taking into consideration the factors listed in the Procedure for Selecting Security Devices.
Procedure for Selecting Security Devices
The [Title of Person Responsible] is charged with selecting security devices for each credit union
office, subject to Board approval. In making such selections, the [Title of Person Responsible]
will consider the following factors:
1. The incidence of crimes in the area in which the credit union offices are located.
2. The location of the nearest law enforcement offices, guards or security personnel and the time
required for such personnel to arrive at the office.
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3. The amount of currency or other valuables exposed to robbery, burglary, or larceny.
4. Other security measures in effect at the credit union offices or within the surrounding areas.
5. The physical characteristics of the credit union's office structures and surroundings, including
the physical vulnerability of the offices themselves and visual obstructions nearby caused by
architectural or landscaping features, which might provide places for criminals to hide.
6. The size of the credit union and number of its employees at each branch.
7. Whether the device meets or exceeds current industry standards. (Consult with law
enforcement officers, security specialists, our bonding company and vendors of security
devices).
Operation of Security Devices
The [Title of Person Responsible] shall establish procedures to ensure that security devices are
operated properly at each credit union office. Such procedures shall include:
1. Training on the operation of security devices for all office personnel.
2. A schedule indicating when each security device should be turned on and turned off.
3. Visual and operational inspection of security device controls to ensure they are working
properly.
4. Logging and retention for at least six months of data recorded on the surveillance systems.
5. Immediate notification to the [Title of Person Responsible] when any security device fails.
Procedures for Testing and Maintaining Security Devices
The [Title of Person Responsible] will schedule tests and preventive maintenance inspections for
all security devices. The tests and inspections will include, but not limited to those listed below.
Testing and Inspecting of Alarm Systems
1. All robbery alarms will be tested semi-annually.
2. All actuating devices will be included in the tests and all office personnel will participate in
the procedure.
3. Preventive maintenance inspections of all burglar and robbery alarm systems will be
conducted at least once every six months by an authorized service contractor.
Procedures for the Operation of Surveillance Systems
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1. The surveillance cameras/monitors located in each credit union office will be actuated during
any robbery or robbery attempts unless it is unsafe to do so.
2. The surveillance camera/monitor will be actuated whenever a credit union employee observes
suspicious behavior of any person in the office.
3. Each employee will receive training in operating the surveillance camera/monitor and what
constitutes suspicious behavior.
Testing and Inspection of Surveillance Systems
1. Camera/Monitor indicator lights and data/footage dials will be checked on a daily basis to
ensure the system is operational and it contains enough storage/film to operate continuously for
at least _________ (three) minutes.
2. Surveillance systems will be tested on at least a monthly basis.
Procedures for Operation of Surveillance Systems
1. Surveillance systems will continuously monitor and record activity in each credit union office.
2. Data from surveillance systems will be retained for a period of at least six months before being
purged and reused.
Testing and Inspection of Surveillance Systems
1. Surveillance systems will be tested daily before opening by recording and playing back one
minute of tape/data to ensure the system is operating properly.
2. VCR recording heads, where applicable, will be cleaned routinely.
Opening and Closing Policies
All employees at each office will be familiar with and follow the prescribed opening and closing
procedures.
Opening Procedures
The first employee to arrive will observe the surroundings of the credit union office. If a
suspicious vehicle or person is observed, the opening will be aborted and the observer will
contact the [Title of Person Responsible] and/or the police.
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2. Upon arrival, the employee will inspect the exterior of the office for signs of forced entry. If
any such signs are visible, the opening will be aborted and the police will be summoned
immediately at ________________________[number for local police].
3. If the inspection reveals no signs of forced entry, the employee will enter the office and relock
the door.
4. Once inside, the employee will inspect all interior areas of the office for intruders or signs of
burglary or other criminal activity.
5. Finding none, the employee will ensure that all security devices intended for use during the
business day are operating, and display a prearranged "all-clear" signal at the drive up window to
advise employees that it is safe to enter the office.
6. No unauthorized personnel will be admitted to the office prior to opening.
7. Arriving employees will ascertain that the all-clear signal has been displayed before leaving
their cars or approaching the entrance.
8. Employees will enter the office briskly and avoid gathering outside the doorway.
9. Once inside the office, no employee will leave the premises until the office is open for
business. If circumstances require an employee to leave the premises before the office is open,
the employee will not be in possession of a key.
10. Office vaults and safes will be opened at the latest practicable time prior to the start of
business in the presence of at least two employees.
11. The all-clear signal, which advises employees that it is safe to enter the office, will be
changed at least once per month on a staggered timetable.
Closing Procedures
1. All employees are instructed to be especially alert for strangers or suspicious behavior at the
end of the business day. Employees will actuate surveillance cameras if suspicions are aroused
and immediately notify [Title of Person Responsible or Manager on duty].
2. At closing time, the office doors will be locked.
3. The door will be relocked after each member leaves.
4. No unauthorized personnel will be admitted into the office after the doors are locked.
5. All currency, negotiable securities, and similar valuables will be secured in the office vault or
safe at the earliest practicable time.
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6. All vital records will be stored in a fire-resistant record safe, container or vault at the earliest
practicable time.
7. The [Title of Person Responsible] will check all interior areas open to the public to assure that
all members have left the building.
8. The manager will check to see that all exterior windows and doors are securely locked and do
an inspection of potential hiding places.
9. After all other employees have left the office, the manager will perform a final inspection of
the office, and assure that all alarms, lighting, and security devices intended for non-business
hours are operating at each office.
Transportation of Currency by Armored Car
1. Currency will not be released for shipment until armored car personnel have been positively
identified.
2. Should the guard be unknown to credit union employees, the guard's identity will be verified
by telephone with the armored car company. (To avoid possible hostage situations, the guard will
not be told that his identity is being checked by telephone.)
3. A signed receipt will be issued for each shipment sent or received.
4. Currency shipments received will be bulk counted in the presence of the armored car
personnel unless the count is guaranteed by the armored car agency.
5. Each shipment will be verified under dual control and secured in the vault or safe immediately
upon receipt.
Servicing Remote ATMs
1. Two or more employees will service the credit union's ATM's during business hours.
2. If a suspicious vehicle or loiterer is observed, the employees will go back in the credit union
office and notify [Title of Person Responsible and/or police].
3. The teller on duty at the drive up window will be the observer for any suspicious activity near
and around the ATM.
4. After servicing the ATM, one employee shall survey the area outside through viewing ports or
CCTV monitor to ensure there is no suspicious vehicle or person (s).
5. Then they will turn on the security system, lock the door and walk back to the credit union
office.
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Visitor Identification and Access to Restricted Areas
1. Access to nonpublic areas within the credit union offices will be restricted by doors and gates
that are locked at all times.
2. An assigned employee will accompany the visitor at all times while the visitor is in restricted
areas of the office. (A manager may make exceptions to this rule on a case-by-case basis.)
3. The visitor's identity and authorization will be verified by telephone to the visitor's company
or office unless credit union personnel know both the visitor and the reason for the visit. To
avoid possible hostage situations, the visitor will not be told of this verification procedure.
Safe-Deposit Security Procedures
1. Before providing access to the vault, each renter's identity will be positively verified.
2. Safe Deposit box cards will be pulled, a signature will be obtained, and current authorization
for entry will be verified.
3. A credit union employee will escort the renter into the vault. Under no circumstances will a
member be left alone in the vault.
4. A credit union employee will never handle a member's key or safe-deposit box unless it is in
full view of the member. The member must always accompany the employee into the vault to
access the box.
5. After the box is accessed, the box door will be locked. The renter's key will remain in his/her
possession.
6. A member will not be permitted to leave his/her box unattended in the safe-deposit box booth.
If the member needs to leave the booth to transact business elsewhere in the credit union, the box
must be secured in the vault. If further access to the box is required, standard procedures will be
followed to regain access to the box.
7. Safe-Deposit box booths will be inspected immediately after each use. Any articles found
during an inspection will be delivered to credit union management and maintained under dual
control.
Safekeeping of Office, Vehicles, Equipment and Supplies Policy
To discourage larcenies involving the theft of office equipment and supplies, and to ensure the
early discovery of such crimes, the CEO will implement the safekeeping procedures prescribed
by this security program at each credit union office.
Safekeeping of Office Vehicles, Equipment and Supplies Procedures
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1. An inventory of all office equipment will be maintained at each credit union office. A record
of the inventory containing a description of the item, make, model and serial number will be kept
in a secure location.
2. An inventory audit of office equipment will be conducted at least annually. Any equipment
found to be missing should be reported immediately to the [Title of Person Responsible].
3. The number of keys to office vehicles will be kept to a minimum and a record of all key
holders will be kept in a secure location.
4. All spare keys and the titles to office vehicles will be secured in a vault or safe.
5. All office vehicles will be locked with the keys removed when not in use.
6. Office supplies will be kept in a locked room/cabinet and allotted to employees on an asneeded basis.
7. Employees will report missing office equipment or other valuables to the their supervisor
immediately.
Policy for the Identification, Apprehension, and Prosecution of Criminals
In order to assist in the identification, apprehension, and prosecution of persons who commit or
who attempt to commit crimes of robbery, burglary, larceny or embezzlement at any office of
[Your] Credit Union, the [Title of Person Responsible] will be responsible for implementing the
procedures prescribed in this security program.
Procedures for Maintaining Records of Crimes
1. A copy of the police report or other detailed record of any robbery, burglary, or larceny at any
credit union office will be kept at the main office and filed with the [Title of Person
Responsible].
2. A Criminal Referral Form will be filed any time an officer, director, employee or agent of the
credit union is suspected of embezzlement.
3. The CEO will report all such incidents promptly to the Board of Directors, unless a member of
the Board is suspected of the crime. If a member of the Board is a suspect, the report will be
made only to the other members of the Board.
4. Records of such crimes and supporting documentation will be kept for at least ten years from
the date of the report.
Procedures for the Maintenance of Bait Money
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1. Bait money will be kept at each teller station and in the vault or safe where currency is kept at
each credit union office.
2. Bait money will consist of used Federal Reserve Notes in nonconsecutive order with no
obvious markings. If the notes are strapped, the dated strap will be kept current.
3. A record of bait money listing the denomination, bank of issue, series year, and serial number
for each note will be kept in a secure location away from currency and other valuables at each
credit union office. The preparer and a second employee who verifies that the record is correct
will sign the record.
4. Periodic audits of bait money will be conducted at each office on a random basis. A record of
these audits will be maintained. All bait money violations will be reported to the [Title of Person
Responsible].
Height Reference Markers
1. Height reference markers or visible strips of tape at a six-foot height will be on doorframes at
all office entrances.
2. All employees will be trained to use these markers to estimate a suspect's height.
Rubbish Retention Procedures
1. All waste paper from the teller stations and other areas where transactions are conducted will
be kept in separate bags or containers, labeled and dated.
2. The labeled bags or containers will be retained for a period of at least one week.
3. After the retention period has expired, discarded documents (e.g. discarded deposit or
withdrawal receipts, voided checks, applications, etc.) will be shredded, incinerated or disposed
of by a bonded recycling contractor who guarantees their destruction.
Security Training Policy
It is the policy of [Your] Credit Union to provide a program of initial and periodic security
training for each employee as prescribed herein.
Security Training – Security Officer
The Security Officer will receive periodic training designed to foster effective administration of
this security program. This training program will keep the Security Officer of current industry
standards for security devices and procedures; criminal activity in the area and security related
issues. The Security Officer shall document training received. The training will include, but not
be limited to:
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1. Periodic consultation with law enforcement officials.
2. Membership in professional security organization (s) and/or attendance at organization
meetings.
3. Periodic consultation with security consultants or security equipment vendors regarding
current industry standards for security devices and procedures.
4. Attendance at security training seminars or classes.
Security Training – Employees
The Security Officer will develop and implement a program to provide initial and periodic
training of employees in their responsibilities under this security program, including operation of
security devices. And in proper employee conduct during and after a robbery, burglary or
larceny. Employees newly hired or transferred to a new position must complete initial security
training before being put on permanent assignment. Periodic training for each employee will be
scheduled at least twice a year. Such training will include both a review of material contained in
the initial training, and new material designed to address current security concerns.
Employee Response to a Burglary or Larceny - Alarm Not Sounded
Each employee will be trained to follow this procedure upon the discovery of an apparent
burglary or larceny:
1. Immediately report the apparent crime to the supervisor, VP/Manager of Member Services,
local law enforcement officials and the FBI.
2. Cordon-off the crime scene. To protect physical evidence, avoid disturbing or handling any
object the criminal may have touched.
3. Cooperate with the police investigation.
4. Discuss the crime only with designated credit union and law enforcement officials.
Burglar Alarm Response
Each credit union office will prepare a list of employees who have keys to the office and are
authorized to respond to a burglar alarm. The list will include the employees' telephone numbers.
Copies of this list will be filed with the [Title of Person Responsible], and the alarm monitoring
service (Security Service). When a burglar alarm is sounded, the monitoring service will contact
an employee on the list to assist in the alarm investigation. Responding employees will be trained
to follow this procedure.
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1. When contacted by the monitoring service (Security Service), proceed to the credit union
office. If the police have not arrived, wait in a locked vehicle a safe distance from the office for
their arrival.
2. After the police have surveyed the exterior of the office for signs of forced entry, permit their
access to the facility and assist in their investigation when they indicate it is safe to do so. (Use
extreme caution because an intruder may be hiding in the office.)
3. Conduct an interior inspection of the office with the police. Thoroughly examine all six sides
of the vault or safe for signs of forced entry.
4. If a burglary has been attempted or committed, immediately notify the CEO and the FBI.
5. Cooperate with the police investigation.
6. To protect evidence, avoid disturbing or handling any object the burglar may have touched.
7. Discuss the crime only with designated credit union and law enforcement officials.
Employee Conduct During a Robbery
In the event of a robbery, the safety of members and employees is of primary importance. All
employees will be trained to follow this procedure during a robbery.
1. Remain composed-try not to panic. Avoid sudden movements or any action that might
provoke the robber.
2. Follow the robber's commands exactly without hesitation or resistance. Avoid making overt
movements other than those ordered by the robber.
3. Activate the silent alarm and include the bait money if it is safe to do so. Any other personnel
should squeeze the hold-up alarm if it can be done so undetected by the robber and accomplished
safely.
4. If the robber demands a certain amount of money, surrender the exact amount. Do not
volunteer additional currency or information about where additional funds are stored.
5. If a note is passed, handle it carefully. Hold it near the edges to preserve fingerprints. Set the
note aside; return it only if the robber asks for it.
6. Be observant. Memorize the robber's physical features, voice, clothing, weapon and any other
distinguishable characteristics, which may be useful for identification. Remember everything the
robber touches and report it later to the police. If more than one robber is present, concentrate on
the nearest one.
7. Lock the doors immediately after the robber (s) exits the office and secure the crime scene.
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8. Call police by telephone immediately after the robber (s) has left the area and provide them
with as much information as possible (i.e., description and direction of travel, get away vehicle,
etc.)
9. Cooperate with the law enforcement investigation by providing witness/victim statements and
completing description forms.
10. Preserve any evidence left behind by the robber or other items found material to the case.
Employee Conduct After a Robbery - [Title of Person Responsible]
After a robbery, the [Title of Person Responsible] should take the following actions. In the event
the [Title of Person Responsible] is absent or incapacitated, another manager may be required to
fulfill these responsibilities. All employees will be trained to follow this procedure:
1. Distribute Robbery Assignment Cards #1 through #6 to available personnel (sample cards are
attached).
2. Meet the victim teller or employee at door or window.
a. If robber is still in view, hold your position to observe direction of escape and
description.
b. Relay this information to assistant calling police.
3. Lock all doors and place Office Temporarily Closed signs in clear view.
4. Wait at the door for police to arrive and control access to building.
5. When certain the robber has left the area or, when instructed to do so by the police dispatcher,
direct an employee to exit the building carrying the All-Clear Placard aloft and wait for the
police.
6. Coordinate the investigation with law enforcement, employees and members.
7. If requested, provide law enforcement with copies of the Record of Bait Money Form for the
currency stolen.
8. Discuss the robbery only with designated law enforcement and credit union officials.
9. Fill out a Description Form/Ident-A-Card of the robber (see attached sample).
Teller Conduct After a Robbery
Steps to follow immediately after a robbery:
Page 17 of 34
1.Remain at your workstation.
2. Secure all remaining currency and valuables.
a. Complete any transaction in process and inform all other members that the office is
temporarily closed for further business.
b. Lock your cash drawers.
3. Protect physical evidence.
a. Rope or block off areas around your station where the robber might have been.
b. Do not touch any object the robber might have handled.
4. List the names and addresses of the last few members you waited on prior to the robbery
(these members may have witnessed the robber's arrival.)
5. Discuss the robbery only with designated law enforcement and credit union officials.
6. Fill out a Description Form/Ident-A-Card of the robber.
Employee Conduct After a Robbery
Certain actions must be taken immediately after a robbery. In some cases (e.g., a robbery
involving a lone note passer) the victim employee may be the only person aware that the robbery
has taken place.
All employees will be trained to follow this procedure…
1. Actuate the silent alarm as the robber is leaving the office, even if it has been actuated once
before.
2. Lock cash drawers to secure any remaining cash or valuables.
3. Notify [Title of Person Responsible] that a robbery has occurred as soon as it is safe to do so.
4. After the robber has left the office, carefully approach a window or door to observe the
direction of escape. Observe any accomplices or witnesses outside. If a vehicle is used, try to
obtain its description and license plate number.
5. Discuss the robbery only with designated law enforcement and credit union officials.
6. Fill out a Description Form or a Description Form/Ident-A-Card of the robber.
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Personnel Given Robbery Assignment Card #1
The employee who is given the Robbery Assignment Card #1 shall complete the following steps
immediately after the robbery:
a.
b.
c.
d.
e.
Lock the doors.
Observe escape vehicle and route (do not exit branch).
Records vehicle license number and description, if known.
Close blinds or curtains.
Post sign on door and at the drive-in window to alert members (see attached
sample).
f. Assign a staff member to stand at the door to admit authorized persons only.
Personnel Given Robbery Assignment Card #2
The employee who is given the Robbery Assignment Card #3 shall complete the following steps
immediately after the robbery:
a. Call the police at 911 to report the robbery.
b. Provide the police dispatcher with your name, the address of the branch and the
telephone number at the branch that the robbery has taken place.
c. Remain on the telephone until instructed to hang up by the police dispatcher.
Personnel Given Robbery Assignment Card #3
The employee who is given the Robbery Assignment Card #3 shall complete the following steps
immediately after the robbery:
a. Notify credit union management at ________________________.
b. Provide the branch location, address and telephone number.
c. Remain on the telephone with management until instructed to hang up.
Personnel Given Robbery Assignment Card #4
The employee who is given the Robbery Assignment Card #4 shall complete the following steps
immediately after the robbery:
a.
b.
c.
d.
e.
Activate the alarm if not already done.
Isolate the victim teller(s).
Lock all teller drawers.
Rope off victim teller window/area.
Place evidence (note) in plastic pouch.
Personnel Given Robbery Assignment Card #5
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The employee who is given the Robbery Assignment Card #5 shall complete the following steps
immediately after the robbery:
a. Ask members and other witnesses present to gather in the member service waiting
area.
b. Instruct them not to discuss their observations with anyone until they have completed
a witness forms and have been interviewed by law enforcement.
c. Distribute staff badges to employees
d. Distribute description forms to all witnesses for completion (see sample attached).
e. List the names, addresses and telephone numbers of all witnesses on a Robbery
Witness Record.
f. If you need assistance, appropriate dialog can be found on the reverse side of Card #5
and is enumerated herein:
1) No Injuries
“We have experienced a robbery. There do not appear to be any injuries. The
robber has left the branch and the doors are locked. Telephone calls to
appropriate law enforcement and credit union personnel are being made.
Please have a seat in the member service waiting area and do not discuss the
robbery with anyone. The police will arrive soon and they will take your
statement. I am going pass out robbery witness forms for you to complete.
The forms are self-explanatory, but if you have any questions, I will be glad to
assist you.”
2) Possible Injuries
”We have experienced a robbery. The robber has left the branch and the
doors are locked. Telephone calls to appropriate law enforcement and credit
union personnel are being made. If you have been injured, please let me know
at once. Please have a seat in the member service waiting area and do not
discuss the robbery with anyone. The police will arrive soon and they will
take your statement. I am going pass out robbery witness forms for you to
complete. The forms are self-explanatory, but if you have any questions, I
will be glad to assist you.”
Personnel Given Robbery Assignment Card #6
The employee who is given the Robbery Assignment Card #6 shall complete the following steps
immediately after the robbery:
a. Pull drive window shades.
b. Recall drive-in tubes.
c. Turn on lane-closed lights.
Page 20 of 34
Dealing With the Media After a Robbery
1. The [Title Of Person Responsible] will be the designated official spokesperson. All other
personnel will refrain from making any public statements.
2. Do not allow members of the press to enter the building until the police and the FBI have
given clearances.
3. Do consult with law enforcement officials before releasing any information about the robbery
to avoid hampering their investigation.
4. If there are no objections by law enforcement officials, the [Title Of Person Responsible] may
release the following information:
a. Their name, title & business telephone number as the official spokesperson.
b. The time the robbery occurred.
c. A brief statement assuring members that all deposits are insured against robbery losses.
Extortion And Bomb Threats
Each extortion attempt and bomb threat is a unique situation. There are common features,
however; and there are common actions, which are appropriate. When and extortion or bomb
threat telephone call is received, the following principles apply:
1. Remain calm; make notes of the conversation, noting the time the call as received, the sex,
race, accent, speech defects, mannerisms, approximate age, any background noises, etc.
2. Obtain as much information as possible from the caller in order to ascertain the nature and
validity of the threat as well as the details of the demand.
3. Always stall for time, always request additional time to meet the demands.
4. If possible, use the attached kidnap/hostage call checklist. Follow the instructions on
the checklist
5. After the caller has hung up, immediately call the following:
a. The FBI,
b. The local police, and
c. The credit union security officer.
6. The attached checklist should be kept immediately available.
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Extortions
In addition to the above, a system should be in effect in all branches whereby the person
receiving the call can signal or otherwise notify another person in the branch to contact
the recipient's family by phone for immediate verification of the seriousness of the threat.
If possible, this should be done while the caller is still on the phone. The credit union has
an extortion pack of $________ of 10's and 20's. None of the straps on the money has
been dated, and each bill has been microfilmed. If we have to deliver cash to an
extortionist, this money will be delivered. Later, it will be relatively easy to track the
cash.
Bomb Threats
In addition to the above, no evacuation should be made without attempting to obtain
authorization from the security officer, the president, or the executive vice president. The
branch manager may take independent action only when he/she cannot contact one of
these people, and the threat is imminent.
Credit Union Officer Personal Profiles
Most kidnap/hostage threats are directed at credit union officers; therefore, confidential personal
identification files will be kept on each officer by the credit union's security officer (see
following pages). The information will be sealed in an envelope, and the information will be
used to compare known information to that stated by the extortion caller.
The security officer will also:
1. Not indicate on the envelopes their intended use.
2. Not allow the profile sheets to be reproduced by anyone.
3. Instruct the officers filling out the forms that they are not to keep a copy.
4. Restrict access to the envelopes to the security officer only. In his or her
absence, the president, executive vice president, or the personnel officer should
have access to the envelopes if an extortion is attempted.
Civil Disorders, Fire, And Floods
Planning in advance for emergencies of these types can reduce risk to employees and loss to the
credit union. Each branch manager will develop specific branch plans that contain the following:
1. Specific duty assignments for each employee.
2. Planned escape routes from the premises and by car from the area.
Page 22 of 34
If Trouble Appears to be Imminent
1. Notify the security officer.
2. Close the branch. Lock all doors and close all drapes and blinds.
3. Place the following into the vault:
a. Currency, including coin if possible.
b. Counter work, including deposits, cashed checks, night deposit bags, cashiers checks,
money orders, travelers checks, records, etc.
c. Working supplies, including cashiers checks, savings bonds, certificates of deposit,
incoming and outgoing collections, etc.
d. Loan records including notes, negotiable collateral, payment cards, etc.
4. If time permits, also place the following secondary items in the vault:
a. Check files (paid checks and deposits for current month).
b. Checking and savings ledgers and printouts.
c. Signature cards of all types.
d. Any other important branch records.
5. The vault is to be closed and locked without setting the time clocks.
If Trouble is Not Imminent
If the branch manager has advance information that trouble is likely, he or she should
prepare by placing the items listed above in the vault except for those items absolutely
necessary to keep the credit union open. Cut cash to minimum levels. Also, call the
security officer and discuss the situation.
Fire Plan
1. Never shout, "Fire."
2. Never use elevators. Keep calm.
3. Remove personnel in immediate danger.
Page 23 of 34
4. Close all doors to confine fire and smoke and to cut down on drafts.
5. Call the local fire department.
6. Combat the fire with extinguishers as much as possible.
7. Placed primary and secondary items in the vault and close it.
8. Clear all hallways and corridors of equipment.
9. Evacuate the building.
10. Proceed to designated assembly area.
11. Set up controls to preclude anyone other than firemen form entering the building.
Security Training Meetings
Each branch manager will conduct regularly scheduled training meetings covering all areas of
security involving that branch. The credit union requires these training sessions be conducted
monthly and that each session last at least fifteen minutes. These meetings should insure that:
1. All employees are familiar with the material contained in this security plan.
2. All employees are properly instructed in the use of the alarm systems.
3. Opening and closing procedures are in effect and are being followed but are changed
periodically. Employees should avoid particular patterns of arrival and departure.
4. All employees are "security conscious," watching for loiterers and suspicious-looking
individuals, especially those seeking change or attempting to open a small account.
5. It is mandatory that all workmen or others requesting access to the credit union provide
proper identification and that this is thoroughly examined.
6. All employees are given holdup cards, description forms, etc. The purpose for each
form should be explained.
7. The importance of keeping cash to a minimum should be explained. Also, each teller must be
trained in handling the robbery pack.
8. The telephone numbers for the appropriate local police department, the local FBI office, and
appropriate fire department station should be posted throughout the credit union.
Page 24 of 34
9. It is of major importance both for the safety of individuals and to the security of the credit
union that each branch employee is familiar with the conduct expected of him in case of a holdup
or any other emergency.
Suspicious Activity Report Form
The Suspicious Activity Report (SAR) is required by NCUA for reporting criminal activity.
Since money laundering and structuring transactions to avoid currency-transaction reporting are
federal crimes, apparent violations of these types should be reported to the NCUA, the US
Attorney, and the local office of the IRS's Criminal Investigation Division. On a voluntary basis,
suspicious currency transactions can be reported to the IRS's (and other law enforcement
authorities). Such "suspicious transactions" might involve deposits and withdrawals in amounts
of less than $10,000 when circumstances suggest an illegal purpose. Certain reporting
requirements are voluntary. For example, losses or apparent violations aggregating less than
$5,000, where the credit union has no substantial basis for identifying a possible suspect, may be
reported, but it is not a mandatory requirement. It is also permissible for a credit union to report
loses under $1,000, where the credit union has a substantial bases for identifying a possible
suspect. Please note, however, when a credit union employee (or agent) is suspected, a report
must be submitted regardless of the amount of money involved.
Page 25 of 34
Sample Letter To Family Members
TO:
The Families of All Credit Union Officers
FROM:
The Board of Directors and the President
RE:
PROCEDURES IN THE EVENT OF A KIDNAPPING
During ______03,there were ____ attempted extortions kidnappings involving officers of
financial institutions. Of these ____ incidents, in ____ cases hostages were actually taken; seven
were credit union employees and ____ were family members of credit union employees. No
hostages died during 2003 and only ____ was injured. When we compare these numbers to the
fact that there are over 11,000 credit unions in the United States and well over a million credit
union employees, the chances of your being involved in a kidnapping or an extortion attempt is
quite remote. Nevertheless, it is still prudent that we take a few precautions and prepare for any
eventuality.
You have an important role to play in our efforts to keep extortionists from being successful.
Before going into these plans, however, let us assure you that your safety, that of your husband,
and that of your children is of utmost importance to the credit union. No one at the credit union,
at any time, will take any action that will jeopardize your safety. All our plans are built around
the cardinal principle: the safety of our people and their families comes first.
THE TELEPHONE REPAIR PLOY
A favorite trick of extortionists is to pretend to be a telephone company employee who is
"working on the line." The telephone company almost never "works on the phone line." The
extortionist will say if the phone rings, let it ring until they can get it repaired. This way your
husband cannot call you because you will not answer the phone.
If an instance similar to this occurs, do not let the individual into the home. Get the person's
name, and the name of his or her supervisor; call the telephone company using the number listed
in the front of the book and not a number given you by the "employee." Verify the repair work.
If the repair work is legitimate, this will only take a few minutes. If it is a ruse, by your actions
you will have foiled the effort, and the extortionist will likely flee.
If the telephone company says no such work is in progress, immediately call your husband and
tell him what has happened and ask him to call the police. This way
your husband has been alerted, the police have been alerted, and the credit union
has been alerted. Under the circumstances you are relatively safe even if the extortionist has not
left the premises --- help will be on its way to you in a matter of seconds.
If you can, leave the house, go to a neighbor's home, or take whatever action you and your
husband have prearranged. The two of you should discuss this letter and work out contingency
plans that best fit your personal situation. It may include going to a neighbor, going to the
Page 26 of 34
children's school, going to a nearby store or church, or locking yourself inside the home. It must
be a plan such that your husband will know what you will do. As soon as you arrive at your
destination, call your husband; the actions the credit union and the police will take depend very
much on our knowing you and the children are safe.
Any suspicious telephone calls or disruption of telephone service should trigger your plan. Any
request that you not answer the phone if it rings should trigger preplanned action. The first step
in this action should be a telephone call to your husband, to his secretary, or to someone else in
the credit union. Let someone near your husband know what is happening immediately.
The odds of your actually being kidnapped are extremely small, less than one chance in a
hundred thousand, but it could happen. If it does, even here statistics strongly suggest that you
will not be harmed. It is quite seldom that credit union family members are harmed and then
only because someone succumbed to panic. If you do not panic and if the people at the credit
union do not panic, in almost all cases you or the children will not be harmed. The extortionists
are after money and they do not want to spend the rest of their lives in prison. They will not be
taking unnecessary chances and neither should you.
Our advice to you is quite simple: Cooperate. If you are taken hostage, do nothing that will
increase the chances of your being harmed. At the same time, to the extent that you can, start
taking mental notes, be prepared to tell the FBI and the police as much as you can about the
incident. Ages, dress, accents, size, car descriptions, recollections of conversations, etc., all
become extremely valuable as the FBI and police try to solve the crime.
The credit union is also developing plans for how the incident will be handled inside the credit
union. These plans are beyond the scope of this letter; we suggest that you and your husband
discuss them in some detail. After these discussions, if you have questions or suggestions, please
call our security officer, Mr. _____________________ at XXX-XXXX. He will be glad to
answer any questions you might have.
Page 27 of 34
Information Security
Program Overview
The purpose of this information security policy is to augment the existing policies on Privacy
and The Bank Bribery Act with supplemental emphasis on protection of information stored and
maintained by this Credit Union. For the purposes of this policy, any transmission of the
information about a member’s account or status with this Credit Union are considered the same
whether it is done orally in person, orally over the phone, via facsimile, e-mail or in any written
form.
The policies have been approved by the Board of Directors and will be followed by management
when implementing the information security policy.
Risk Assessment
The credit union will assess risks that may threaten the security, confidentiality or integrity of
member information or member information systems by:
1. Identifying all reasonably foreseeable internal and external threats
2. Determine likelihood and potential damage of internal and external threats
3. Determine sufficiency of the credit union’s policies, procedures and member information
systems to control the identified risk.
Consideration will include Employee controls, Physical Controls, Hardware Controls, Software
Controls, Authentication Controls, Electronic Mail Controls, Information Transmission Controls,
Internet Controls, Service Provider Controls
Information Disposal Controls, Remote Access Controls.
Risk Control
Identified risk will be controlled by establishing and maintaining written procedures designed to
implement, maintain and enforce the information security program.
The credit union will monitor, evaluate, and adjust, as appropriate, the program in light of any
relevant changes in technology, internal or external threats to information, and the credit union’s
own changing business arrangements with regular testing of key controls, systems, and
procedures. This directive will concern itself with specific threats, as they exist now.
Staff Training
Employees are granted access to information commensurate with their position and will be
trained with regard to their responsibilities under this policy.
Page 28 of 34
Service Provider Arrangements
The credit union will exercise appropriate due diligence in selecting its service providers to
ensure appropriate measures are taken by the provider to protect the confidentiality of the
member’s non public information.
Review
Reports shall by made regularly (no less than annually) to the Board of Directors on the current
status of the information security Program.
General Prevention
The release of any information, other than merchant verification of funding in a member’s draft
account, must have written authorization by the member. This authorization can be done by
facsimile. E-mail signatures, however, are not sufficient.
Specific Threats to Securing Information
Several areas of immediate concern are dealt with specifically herein, however, two specific
areas of concern will be addressed relating to computer hackers and infections by computer
viruses.
Hackers-Unauthorized Access to the Credit Union’s Computers
There are two avenues a hacker could enter the ________________Credit Union’s computer.
1. Through the Credit Union’s modem/broadband connection on the main computer. This
connection has a mechanical switch box/remote access system (RAS). (This switch [RAS]
should be turned in a non-support position or turned-off when not needed and whenever the
Credit Union is closed.)
2. Through computers on the Credit Union network, which have access to the
__________________ Internet/Intranet. The firewalls between the Credit Union’s server and the
Internet/Intranet are the weakest area for a threat to penetrate. The
__________________________ (IT Department/Information Services Security Team) monitors
all computer activity coming in through its system and has procedures in place to detect and
block unauthorized entry into the system.
Virus and Information AttackAll employees are cautioned not to open emails from outside the credit union network where
they do not know the sender. Unfortunately, this is not much of a deterrent to computer viruses.
Therefore, the credit union’s server and all computers that are connected to the server are
installed with anti-virus software that provides for automated updates to all network computers
Page 29 of 34
on a daily basis. Employees shall insure that this anti-virus software remains active on their
computers, i.e., under no circumstances shall the anti-virus software be deactivated.
Once a virus is detected by the Virus Scan or suspected due to the behavior of the computer, the
________________________ I/T department/Information Security Team should be contacted
and their instructions followed. If possible, the affected computer shall be disconnected from the
server/other computers so as to isolate the virus’ effects.
Employees who discover that their computer is infected with a virus shall follow the instructions
of the ______________________________ [IT Department] in order to correct the problem.
(All efforts should be made to contain the virus in the computer it initially infected.)
The IT staff currently backs up the data processing system every night and each desktop
computer is backed up ______________________ (daily, Fridays, etc} These backups shall be
used to restore the computer system in the event of a loss of data resulting from a major disaster
or system failure. In some instances all work processed since the last backup may have to be
manually re-entered. This decision will be made by the IT Department after the system has been
restored from the backup tape.
Pretext Callers- Federal Laws apply to those persons who try to obtain personal financial
information under false pretenses. Callers should be told that the information requested is not
available over the phone. If a person is trying to obtain information on someone else’s account in
person, the staff should attempt to distract that person and notify management who will alert the
police.
Verifications over the phone- the staff of this Credit Union should make a practice of not giving
information over the phone other than merchant verification of funds on draft accounts. This will
discourage pretext callers and the volume of member callers who have other means to access
their account information (Audio Response, ATM’s, Internet, etc).
Other Sources Of Reference:
Please refer to any of the following for further guidance in this matter;
The ________________________________Disaster Recovery Plan
The ______________________________________________________________
The _______________________________ Credit Union’s Bylaws, Bank Bribery Act Policy,
Security Policy and Privacy Policy.
Various Government and NCUA Letters, Directives and Policies on these issues, i.e.,
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
_____________.
Page 30 of 34
FRAUD POLICY
The _________________________________________ Credit Union considers any form of
fraud or dishonesty on the part of its employees as totally unacceptable conduct. Acts which are
considered to be either fraudulent or dishonest include, but are not limited to:
1.
Manipulation of loan accounts, documents, computer records, and share or share draft
accounts.
2.
Theft of any kind, including stealing from members’ accounts, overpayment of
dividends, and creating fictitious loans.
3.
Check/share draft kiting.
4.
Forgeries.
5.
Unauthorized or unapproved salary advances or overtime reimbursement.
6.
Intentional violation of credit union rules, internal controls, regulations, or
procedures.
7.
Intentionally failing to secure collateral, to properly record a security interest in
collateral, or pledging a member’s shares as collateral without that member’s
permission.
8.
Granting or requesting preferential treatment for ANYONE.
I have read the above Fraud Policy. I understand that management will not tolerate fraudulent or
dishonest activities of any kind and that I am not to engage in acts of fraud or dishonesty while
employees at the ___________________________________________________ Credit Union.
Dated this _______________________ day of ______________________, 20_____.
___________________________________
Witness
Page 31 of 34
_________________________________
Employee
Security Incident Report
Date Reported
Reported by
Phone
Date of Incident
Time of Incident
___a.m. ___p.m.
Department
Amount of Loss
$
ATM?
___ yes ___ no
Building/Branch
Case File No.
Type of Incident
__Assault
__Bomb Threat
__Burglary
Injuries?
___yes ___no
Victim Name:
Home Phone:
__Criminal Trespass
__Robbery
__Larceny
Weapon used?
___yes ___no
__Scam
__Suspicious Activity
__Other_________________________
Victim?
___Member ___Visitor ___Employee ___CU ___Other
Address:
Business Phone:
If member, account no.:
Police Report
Police Notified:
__yes __no
Officer:
Suspect Name:
Incident Details:
Page 32 of 34
Time:
_____ a.m. p.m.
Agency:
Report No:
Suspect
Arrested?
Arrest Date:
__yes __no
Court Date:
Insert credit union name and logo
NOTICE TO ALL
MEMBERS
THIS OFFICE IS TEMPORARILY
CLOSED DUE TO A ROBBERY.
THE NEAREST BRANCH OR
SERVICE CENTER IS AT
(insert address)
WE APOLOGIZE FOR THIS
INCONVENIENCE AND
APPRECIATE YOUR
COOPERATION.
Page 33 of 34
Robbery Witness Record
Branch:
Date:
Name
Page 34 of 34
Address
Telephone
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