List of 15 Questionable Practices Documented

The Florida Office of Financial Regulation discovered 15 practices at Eastern Financial Florida Credit Union that either needed immediate attention or complete overhauls.According to the March 19 cease and desist order, they are:Operating without effective leadership oversight executive management supervision and direction from the board of directors to prevent unsafe and unsound practices and violations of laws rules regulations and guidance;Operating without adequate core deposits to ensure it can meet its funding obligations as they become due without the mandatory use of borrowed funds to achieve and maintain the necessary liquidity under all circumstances;Operating without a specifically described and effective capital maintenance plan;Operating without adequate polices procedures and internal routines and controls regarding capital liquidity earnings and lending;Operating without adequate loan underwriting standards or a loan review program that would ensure sound loan underwriting risk assessment and risk management;Operating with an excessive level of adversely classified assets;Operating without adequate policies to properly fund the allowance for loan and lease loss account;Operating with an excessive level of concentrations in the member business loan portfolio;Operating in violation of federal and state laws rules regulations and guidance concerning financial institutions;Operating without adequate oversight by the CU’s board of directors and supervision by executive management to prevent violations of the Bank Secrecy Act and anti-money laundering requirements;Operating without an effective system of internal controls to ensure ongoing compliance with BSA/AML requirements;Operating without an effective system of independent testing for compliance with BSA/AML requirements;Operating without an adequate BSA/AML requirements program for the appropriate personnel;Operating without an effective customer identification and verification system that complies with section 102.13 of the rules and regulations of the Department of the Treasury;Operating without an adequate system for detecting and reporting suspicious activity.–[email protected]