UNITED STATES OF AMERICA

NATIONAL CREDIT UNION ADMINISTRATION

NATIONAL CREDIT UNION ADMINISTRATION BOARD

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In the Matter of the )

Cease-and-Desist Order of )

) Docket No. 07-0203-II

)

Dover N.J. Spanish American )

Federal Credit Union )

Respondent. )

)

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CONSENT CEASE AND DESIST ORDER

The National Credit Union Administration Board ("NCUA Board"), by and
through its undersigned counsel, and Dover N.J. Spanish American Federal
Credit Union (\"the Credit Union\") hereby stipulate and agree as
follows:

1\. [Consideration]{.underline}. The National Credit Union
Administration is of the opinion that grounds exist to initiate an
administrative cease and desist action against the Credit Union pursuant
to Section 206(f)(1),(q)(3) of the Federal Credit Union (FCU) Act, 12
U.S.C. §1786(f)(1),(q)(3). The Credit Union, without admitting or
denying that said grounds exist (except those set forth as to
Jurisdiction in paragraph 2), desires to avoid the time, cost, and
expense of administrative litigation. Accordingly, the Credit Union
consents to the issuance by the NCUA Board of a Cease and Desist Order
(\"Order\").

2\. [Jurisdiction]{.underline}.

\(a\) The Credit Union at all times relevant hereto, was a federally
chartered and insured credit union within the meaning of 12 U.S.C.
§1752(1) and 12 U.S.C. §1752(7). Accordingly, the Credit Union is
subject to supervision of the NCUA Board. 12 U.S.C. §1756.

\(b\) The Credit Union's directors, officers, committee members, and
employees are \"institution-affiliated parties\" within the meaning of
Section 206(r) of the Federal Credit Union Act, 12 U.S.C. §1786(r).

\(c\) Pursuant to the authority vested in the NCUA Board under Section
206(e) of the Federal Credit Union Act, 12 U.S.C. §1786(e), and Part 747
of the National Credit Union Administration Rules and Regulations, NCUA
is the appropriate Federal agency to maintain enforcement proceedings
against the Credit Union and any institution-affiliated parties.
Therefore, the Credit Union, its directors, officers, committee members,
and employees are subject to the authority of the NCUA Board to initiate
and maintain enforcement proceedings against them.

3\. [Consent]{.underline}. The Credit Union consents to the issuance by
the NCUA Board of the accompanying Order. The Credit Union agrees that
the Order complies with all requirements of the Federal Credit Union Act
and consents to the following terms and conditions:

The Credit Union (including all directors, committee members, officers,
and employees) shall immediately:

1.  Within 30 days of this Order, engage an individual or firm of Bank
    Secrecy Act/Anti-Money Laundering (BSA/AML) specialists as a
    consultant to assist you in correcting BSA/AML compliance program
    deficiencies. The BSA/AML consultant must have the requisite
    expertise with current knowledge of BSA/AML compliance requirements
    for financial institutions. Consultants must have an AML specialist
    designation, experience litigating BSA suits or other factors
    evidencing BSA/AML competency. The specialist must also have an
    established history of providing such specialized services to
    financial institution clients.

2.  Complete a comprehensive BSA/AML risk assessment with the assistance
    of a BSA/AML specialist within 30 days of this Order. Develop and
    maintain a list of high and moderate risk members based on the
    results of the risk assessment. Ensure account activities of high
    risk members are reviewed and analyzed monthly and moderate risk
    members are reviewed and analyzed quarterly.

3.  Designate a competent, full-time BSA Compliance Officer (BSA
    Officer) with delegated authority and resources to implement and
    enforce BSA policies and procedures and to ensure compliance with
    all material aspects of the BSA and its implementing rules and
    regulations within 10 days of this Order. Take immediate action to
    ensure that the BSA Officer obtains all training necessary to
    knowledgably perform duties and oversee daily compliance.

4.  Approve a detailed job description for the BSA Officer and submit a
    copy of the job description to the NCUA Region II Regional Director
    in Alexandria, Virginia within 30 days of this Order.

5.  Ensure cash transaction and outgoing wire monitoring spreadsheets
    are updated daily. Ensure all BSA/AML activity monitoring tools are
    analyzed at least weekly.

6.  Develop and implement internal controls and additional transaction
    activity monitoring tools to ensure all reportable transactions are
    promptly identified, researched, and reported. Ensure monitoring
    tools include monetary instrument sales and redemptions, incoming
    wire transfers, automated teller machine transactions, and any other
    operational areas identified in your BSA/AML risk assessment that
    require monitoring.

7.  Ensure all required reports, including Currency Transaction Reports
    (CTRs) and Suspicious Activity Reports (SARs), are completed timely,
    accurately and completely.

8.  Direct the BSA Officer to apply for and begin using FinCen's BSA
    Direct E-Filing System within 15 days of this Order at
    [http://www.fincen.gov](http://www.fincen.gov/). Ensure appropriate
    personnel have access to the BSA Direct E-Filing System based on job
    duties and responsibilities.

9.  Ensure all CTR and SAR information is kept confidential and that all
    individuals named as suspects on SARs are never informed of the
    filing of SARs.

10. Dedicate sufficient staff to complete FinCEN mandated back-filing to
    2001 within 60 days of this Order. Consider using temporary
    employees to perform routine Credit Union duties (teller, member
    service representative, bookkeeping) while Credit Union staff
    performs this review of confidential member activities.
    Confidentiality is imperative for all SAR filings.

11. Ensure Credit Union staff complete a check of all members against
    the Office of Foreign Assets Control Specially Designated Nationals
    (OFAC SDN) list monthly.

12. Ensure all personnel responsible for checking names against the OFAC
    SDN list are provided appropriate training for the Credit Union's
    OFAC software within 30 days of this Order.

13. Obtain OFAC training for all officials, including, but not limited
    to, operational management, staff, and board members within 30 days
    of this Order.

14. Direct the BSA Officer to obtain and research all FinCen Section
    314(a) information sharing requests on a timely basis. Direct the
    BSA Officer to contact FinCEN to obtain any missed requests and to
    search applicable Credit Union records within 10 days of this Order
    and weekly thereafter.

15. Direct the BSA Officer to establish written Customer Identification
    Program (CIP) processes to validate identifying information received
    from members within 15 days of opening an account. Restrict services
    to basic share activity until validation occurs. Engage a service
    provider or obtain services directly from the Social Security
    Administration to validate the authenticity of social security
    numbers (SSNs) and employer identification numbers (EINs).

16. Establish processes to ensure all report errors or mismatch
    notifications from the IRS Enterprise Computing Center-Detroit are
    researched and addressed fully, appropriately and timely.

17. Direct the BSA Officer and sufficient staff to verify the validity
    of SSNs, EINs, and Individual Tax Identification Numbers (ITINs) for
    all Credit Union members who joined the Credit Union since January
    1, 2000. Ensure SARs are filed for all SSNs, ITINs and EINs that the
    Credit Union is unable to correlate with member information received
    within 90 days of this Order.

18. Establish written policies and procedures to:

-   Identify all money services business (MSB) members,

-   Conduct a risk assessment for each MSB to determine the risk levels
    associated with each relationship and when enhanced due diligence is
    necessary,

-   Conduct appropriate and ongoing due diligence on MSB accounts as
    necessary. (This includes a request and review of each MSB's written
    BSA/AML and CIP policies and procedures and copies of annual BSA/AML
    compliance program independent testing and audit reports),

-   Ensure MSB accounts are appropriately monitored for suspicious
    activity and to ensure transactions conducted in or through Credit
    Union accounts are consistent with the MSB's registered activities,

-   Confirm appropriate and current FinCEN registration, and,

-   Confirm agent status.

> Ensure all steps above are completed for all MSB accounts within 30
> days of this Order or discontinue the account relationship.

19. Ensure all business accounts or personal accounts with business
    activities are consistently identified on the Credit Union's CUSA
    core data processing system within 90 days of this Order. This
    includes accounts for professional service providers, cash-intensive
    businesses and all other business accounts.

20. Develop and implement due diligence and account monitoring processes
    for business accounts based on the Credit Union's risk assessment of
    account activities within 60 days of this Order.

21. Develop and implement a comprehensive BSA/AML training program
    within 45 days of this Order. Include the following elements in your
    BSA/AML training program and materials:

-   Credit Union directors' and senior management's commitment to
    ongoing education, training and compliance.

-   Employee accountability to ensure BSA/AML compliance.

-   Risk-based training commensurate with the specific risks of Credit
    Union products, services, members and geographic locations.

-   Training frequency requirements.

-   Documentation of training attendance and maintenance of training
    materials.

-   Credit Union policies, procedures, processes, and new BSA/AML rules
    and regulations.

-   Forms, examples, and identification of money laundering and
    terrorist financing as it relates to suspicious activity.

-   Penalties for noncompliance with internal policies and regulatory
    requirements.

22. Within 120 days of this Order, engage the services of a qualified,
    independent third party to conduct BSA/AML compliance program
    independent testing. Ensure the testing is completed and reported
    within 180 days of this Order. Require additional BSA compliance
    program independent testing at least annually thereafter.

4\. [Waivers]{.underline}. The Credit Union waives its right to the
administrative hearing provided for in Section 206(e)(1) of the Federal
Credit Union Act, 12 U.S.C. §1786(e)(1). The Credit Union waives its
right to seek judicial review of the Order or otherwise challenge the
validity or legality of the Order.

5\. [Finality]{.underline}. The Order is issued pursuant to Section
206(f)(1),(q)(3) of Federal Credit Union Act, 12 U.S.C.
§1786(f)(1),(q)(3). Upon its issuance by the NCUA Board, it shall be a
final Order, effective and fully enforceable by the NCUA.

WHEREFORE, in consideration of the foregoing the undersigned, on behalf
of the NCUA, and the Credit Union execute this Stipulation and Consent
to Issuance of a Cease and Desist Order.

By: [Herbert S. Yolles /s/]{.underline}\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_[2/21/07]{.underline}\_\_\_\_\_\_\_

National Credit Union Administration Date

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\_\_\_\_\_\_[2/27/07]{.underline}\_\_\_\_\_\_\_\_\_

Angel Mendoza, Jr. President Date

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Roberto Piccolo, Vice-President Date

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Alvaro Hernandez, Secretary Date

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Beatriz Villada, Treasurer Date

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Dagoberto Lopez Date

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Francisco De Jesus, Sr Date

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Board Member-Vacant Date