**REGULATORY ALERT**

**NATIONAL CREDIT UNION ADMINISTRATION**

**1775 DUKE STREET, ALEXANDRIA, VA 22314**

**DATE: February 2005 NO.: 05-RA-04**

**TO: All Credit Unions**

**SUBJECT: Web-based 314(a) Secure Communication System**

Dear Board of Directors:

The purpose of this Regulatory Alert is to notify you that the Financial
Crimes Enforcement Network (FinCEN) is changing its process for email
delivery of 314(a) information. Receipt and timely response to 314(a)
requests is required by the U.S.A. Patriot Act.

If your credit union receives 314(a) transmissions via fax, your credit
union will continue to receive fax transmissions. No change will occur
in the process for fax transmission of 314(a) information.

For credit unions receiving 314(a) transmissions via email, FinCEN will
change to a web-based system on March 1, 2005. All credit unions
currently receiving email transmissions must register at
<https://www.fincen.gov/314a/> to be provided with access to FinCEN\'s
web-based 314(a) secure communication system.

Once registered, credit unions will access and report on 314(a)
information using the web-based 314(a) secure communication system.
Emails with attached lists of 314(a) information will no longer be sent
to credit unions. Therefore, to comply with 314(a) provisions, credit
unions must either use the web-based system or receive 314(a) requests
via fax.

[All credit unions receiving email transmissions should register on the
web-based 314a secure communication system before March 1,
2005.]{.underline}

Information about the registration process was provided via email to
credit union primary points of contact by FinCEN on January 28, 2005.
Subsequent guidance on the upcoming conversion to a web-based system and
the establishment of user accounts may be found on FinCEN's Web site,
<http://www.fincen.gov/fininstnotice02042005.pdf>

On February 22, 2005, NCUA will provide both the primary and secondary
U.S.A. Patriot Act contacts reported on the December 2004 call report to
FinCEN. Currently, only primary points of contact are provided. Starting
the week of February 28, 2005, credit unions should be able to establish
user accounts for both primary and secondary points of contact reported
on the December 2004 call report.

NCUA is providing the attached list of questions and answers. These
questions reflect common inquiries by credit union staff members,
involved with the receipt and review of 314(a) information.

If you have questions, please contact FinCEN, the appropriate NCUA
regional office, or your state regulator.

> Sincerely,
>
> /s/
>
> JoAnn Johnson
>
> Chairman

Enclosure

[Questions and Answers: 314(a) information, February 2005]{.underline}

**After registration on the 314(a) web-based system, will it still be
necessary to report U.S.A. Patriot Act point of contact information on
the quarterly call report?**

Yes, credit unions must continue to report U.S.A. Patriot Act points of
contact on the quarterly call reports. As a control over access, FinCEN
will periodically match call report point of contact information to user
information. If a user email address does not correspond to a call
report point of contact email address, the user will be denied access to
the web-based system.

**Can we have more than two user accounts for the 314(a) web-based
system?**

No. A credit union can only report two (primary and secondary) points of
contact on the call report. Authorized points of contact must be
reported to FinCEN through call report data submitted by NCUA or state
regulators. NCUA uses an automated system to capture and report point of
contact information to FinCEN for federally insured credit unions; only
data contained on a call report is reported.

Credit unions that need to provide FinCEN 314(a) information to multiple
users may provide a non-personal email address, which can be accessed by
multiple staff members, for one of the points of contact reported on the
call report. This non-personal email address may then be used to
establish an account for the web-based system. If a credit union chooses
to establish this type of account for the web-based system, there must
be strong controls over the account. A list of authorized users should
be maintained for the account, and the password for the account should
be changed on a regular basis and when a user is no longer authorized to
review 314(a) information.

FinCEN will only discuss specifics about requests and access to the
web-based system with individuals named as a point of contact within the
call report. If a non-personal user account is established, one
individual must be named as point of contact for communication with
FinCEN.

**How does a credit union change 314(a) point of contact information
between call report filings?**

Federal credit unions should contact their district examiner or NCUA
regional office. A list of regional office contact information is
available on the NCUA web site at
<http://www.ncua.gov/AboutNCUA/org/OrgChart.htm>. Select the regional
office that oversees the state where the main branch of the credit union
is located. Upon being provided with updated point of contact
information, NCUA will upload a revised call report. Then, the revised
point of contact information will be provided to FinCEN with the next
report to FinCEN.

State charted credit unions should contact their state regulator. State
regulators can upload a revised call report to the NCUA host system at
any time. The revised call report point of contact will be included with
NCUA\'s next report to FinCEN.

NCUA reports point of contact data to FinCEN every two weeks. Depending
on when revised data is provided to NCUA, there may be a two week lag in
its report to FinCEN. NCUA reports new call report data after
validation. For example, NCUA anticipates reporting December 2004 call
report data to FinCEN during the week of February 21, 2005. After the
report, it takes several days for FinCEN to test and load the data.

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