As part of our fundamental commitment to maintaining and enhancing our reputation as a highly ethical financial institution, it is our policy to strive to do business only with individuals and/or organizations of good reputation. We believe that every financial institution should assume that it is a potential target for use by organized crime and other illegal enterprises to launder the cash proceeds of their activities. We also believe that every financial institution should do its part in the "War on Terrorism." Our financial institution is committed to implementing a strong and effective program to comply with the spirit and specific provisions of all laws and regulations and also to the implementation of a know-your-member program.

In view of the proceeding, we the Board of Directors, establish the following policy to be developed by management.

This Credit Union will comply with provisions of the Bank Secrecy Act, Currency and Foreign Transaction Reporting Act, and the USA Patriot Act.

1. Currency Transaction Report (CTR) (IRS Form 4789).
1. A CTR must be filed within 15 days if a transaction or series of transactions:
1. Involves more than $10,000 in either cash coming in or cash going out, and
2. Is conducted by, or on behalf of, the same person, and
3. Is conducted on the same business day.
2. Aggregate amounts totaling more than $10,000 will be reported.
3. Completed CTRs will be filed by the Credit Union Manager.
4. Completed CTRs will be sent to: IRS Detroit Computing Center, Attn: CTR, P. O. Box 33604, Detroit, MI 48232-5604.
5. The CTR must be kept on file for at least 5 years.
6. It may be necessary to file both a CTR and a SAR should the transaction(s) be both suspicious and over $10,000 in cash.

2. Suspicious Activity Report (SAR) (Treasury Form TD F 90-22.56).
1. A SAR must be filed within 30 calendar days after becoming aware of any suspicious transaction.
2. A SAR will be filled out when:
1. Any transaction conducted or attempted by, at, or through this Credit Union involving or aggregating funds or other assets of at least $2,000 (except as described in section "b" below) when the Credit Union knows, suspects, or has reason to suspect that:
1. The transaction involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity (including, without limitation, the nature, source, location, ownership or control of such funds or assets) as part of a plan to violate or evade any Federal law or regulation or to avoid any transaction reporting requirement under Federal law or regulation;
2. The transaction is designed, whether through structuring or other means, to evade any regulations promulgated under the Bank Secrecy Act; or,
3. The transaction has no business or apparent lawful purpose and the Credit Union knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.
2. To the extent that the identification of transactions required to be reported is derived from a review of clearance records or other similar records of money orders or traveler's checks that have been sold or processed, an issuer of money orders or traveler's checks shall only be required to report a transaction or a pattern of transactions that involves or aggregates funds or other assets of at least $5,000.
3. A completed SAR will be filed by the Credit Union Manager.
4. Completed SARs will be sent to: Detroit Computing Center, Attn: SAR-MSB, P. O. Box 33117, Detroit, MI 48232-5980.
5. A copy of the sent SAR must be kept on file for at least 5 years.
6. It may be necessary to file both a SAR and a CTR should the transaction(s) be both suspicious and over $10,000 in cash.

3. Customer Identification Program (CIP).
1. Positive Identification Documents (PID) are required whenever a person joins the Credit Union. PIDs are both the membership card and additional documents as listed below.
2. The membership card must show the member's name and date of birth.
3. Additional documents shall include:
1. Photocopy of the member's valid driver's license.
2. Photocopy of the member's Social Security card.
3. Proof of current address (if different from driver's license).
4. A credit report (if 18 years of age and older).
4. If the above items are not available, the following can be substituted:
1. In lieu of a current address (either personal or business), the individual can use an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual.
2. In lieu of the Social Security number, a current U. S. Passport number may be used.
3. If a minor, the parent or guardian's driver's license may be use, but the minor's Social Security card photocopy is required. The Membership Responsibility Agreement must also be on file. A credit report will not be required on the minor.
5. When opening the Primary Share Account, a file folder will be used to retain the additional documents.
6. The folder will be kept in a pending file status until all documents are obtained.
7. The Membership Officer is responsible for verifying that all documents are received and filed.
8. Once all documents are received, the file will be kept as long as the person is a member of the Credit Union, or five years, whichever is greater.
9. Should the needed documents not be obtained within 60 days of opening the Primary Share Account, the member's account will be closed.

1. These services well be monitored in such a way as to readily identify the purchasers/transmitters and their transactions. Chronological logs will be maintained that will show the following information (mandatory in connection with amounts greater than $3,000):
1. Name of purchaser/transmitter
2. Address (if purchaser/transmitter is not a member of the Credit Union)
3. Purchaser's/transmitter's account number or social security number
4. Purchaser's/transmitter's date of birth (if purchaser/transmitter is not a member of the Credit Union
5. Date of purchase/wire transmission
6. Type of instrument purchased
7. Serial number of each purchased instrument
8. Dollar amount of each purchase/transmission by currency
9. Method used to verify identity of purchaser/transmitter
10. Indication if the transaction is apart of a multiple sale during one business day

2. The chronological logs will be retained for at least 5 years.

1. This program will be audited annually. The Supervisory Committee or the external auditing firm may be used to complete the audit.
2. Written results of the audit will be kept on file for at least five years.

The Credit Union may exempt certain listed transactions from this policy.

1. These exemptions are:
1. Currency deposits or withdrawals from an existing account by an established member who is a U.S. resident and operates a sports arena, race track, amusement park, restaurant, hotel, licensed check-cashing service, vending machine company or theater.
2. Currency transaction by local or state governments, or the U.S. Government or any of its agencies or instrumentalities.
3. Withdrawals for payroll purposes from an existing account by an established member who is a U.S. resident and operates a business that regularly withdraws more than $10,000 in order to pay its employees in currency.

2. A centralized list of all exemptions granted by the Credit Union will be kept by the Membership Officer.

1. The Assistant Manager is designated as the BSA Compliance Officer.
2. BSA Compliance Officer Duties:
1. Ongoing staff training
1. To see that existing staff is made aware of any updates or changes when applicable
2. To train new staff, directors and committee members regarding the Credit Union's procedures
2. Creating and maintaining record keeping systems
3. Reviewing daily transactions
4. Reviewing reporting forms
5. Creating and maintaining exemptions lists (if any)
6. Creating and maintaining tax identification number lists

3. Responsibilities may be delegated by the BSA Compliance Officer to other Credit Union staff as deemed appropriate and approved by the Credit Union Manager.
4. The BSA Compliance Officer will act as the contact person for answering requests for information and coordinating compliance examinations.
5. The BSA Compliance Officer will be responsible for keeping up to date with any and all changes in the regulations and the impact on this Credit Union's operations of major court decisions regarding the BSA Act and its implementing regulations.

1. The staff training program will be ongoing to insure that amended procedures are complied with and that new employees are adequately trained.

2. Employees will be provided a check list to serve as a reminder to ask, verify and determine the "true identity" of the persons(s) and the transaction(s).

3. Training will also include information on the USA Patriot Act including the Customer Identification Program as outlined in Paragraph III.C. above.

4. The BSA Compliance Officer will assure that the requirements of this policy are reviewed by the staff at least annually.