About Jim Vilker, NCCO

Since joining the credit union industry in 1985, Jim Vilker has been a strong advocate of managing and educating staff in compliance and audit functions. He launched his career as an examiner where he gained knowledge and depth of insight into regulatory compliance requirements of credit unions. Jim studied a broad scope of business and operational procedures leading to a deep understanding of best practices significant to credit union audit activities.
Over the next eight years Jim was actively entrenched in the business as Executive Vice President of a credit union. Jim has earned his NCCO certification through specialization in the field of auditing and compliance. His software product of choice serving as the compliance and auditing tool, was the forerunner of the current CU*BASE.
Jim’s tenure at CU*Answers began in 1998 where his knowledge and skills were immediately recognized as the CUSO’s resident advisor on regulatory compliance and audit functions. Jim has been instrumental in developing the strategic Audit Link business, educating clients through an online Advisor newsletter and designing premier training plans for clients of Audit Link and internal staff of CU*Answers’ credit unions. His experience in working with clients and CU*BASE tools uniquely qualifies him to write and instruct in the monitoring of regulated activities.

Articles by Jim Vilker, NCCO

CU*Answers Introduces Network Compliance Teacher

Audit Link, a division CU*Answers Management Services, has published its first addition of the Network Compliance Teacher. The magazine is a collaborative effort of CU*Answers and the compliance professionals of their credit union clients. Collectively they determine a theme, author the articles, and publish the magazine to all CU*Answers clients free of charge. “The articles [...]

Introducing The Network Compliance Teacher Newsletter

Audit Link is pleased to announce the Network Compliance Teacher Newsletter. The Network Compliance Teacher Newsletter is designed as a collaborative effort between Audit Link and the compliance professionals of our client credit unions, with an audience of every credit union staff member in our network who has to deal with the regulations affecting the [...]

Regulation E and e-Statements

The CU*Answers mantra has always been “we make the tools, not the rules.”  Regulation is always subject to interpretation and in some cases business risk.  When we developed the e-Statement platform, credit unions requested we give them the ability to physically enroll members at the time of account opening.  This request came from those credit [...]

Vilker’s Dirty Dozen

This is a list of suggested projects that have made it to my radar and are currently being discussed here at CU*Answers. As you read through the list, you’ll notice a few that have been implemented already. Some are in process with our QC team, and still others are at the stage of specifications being [...]

1. Abnormal Activity Monitoring

Activity – Excessive ACH activity on an account could indicate an account defined as personal is being used as a business account. Most transactions come from ATM providers, while others are excessive NSF returns. The credit union is often unaware that excessive and abnormal activity is occurring. These could be commercial accounts flying under the [...]

2. BSA Enhancement: ATM Activity

Activity – Member uses an ATM to deposit and withdraw funds to avoid scrutiny of the BSA tracking system. Solution – Update the system to monitor for ATM cash activity in the BSA file. Model it after the feature used in shared branching activity. Status – We went ahead and analyzed the data that is [...]

3. BSA Enhancement: Joint Owner Activity

Activity – Member avoids currency transaction monitoring by depositing cash into multiple accounts, some on which the member is the primary account holder and others as only a joint owner. Solution – Enhance the BSA monitoring feature to enable account tracking on every account connected to the Social Security number of every member, regardless of [...]

4. BSA Enhancement: Layering

Activity – Member gets a line of credit and wires the money out of the credit union, or they purchase giftcards through the miscellaneous receipts process. Member then makes large payments on the loan and each time the available limit grows, another wire transfer is made. Many times it is a wire. If the member [...]

5. Check Cashing Function

Activity – Member comes in to cash a check and the teller uses the check cashing function which does not write out a transaction on the member’s account. Four issues: First, in most states this is prohibited on business accounts. Second, when reviewing BSA activity the auditor must also review the teller audit log. Third, [...]

6. Check Kiting Monitoring

Activity – Members who make deposits at one institution using funds drawn from another financial institution, when that account has no balance, are guilty of Check Kiting. These members are “playing the float.” Viewed as suspicious in most cases, tellers are encouraged and even obligated to place extended holds on these accounts. Solution – Review [...]

7. Critical Field Monitoring

Activity – Currently credit unions must review the file maintenance logs to determine if the changes made to member accounts were completed correctly and with the proper authority. Solution – Create a screen where the credit union could chose up to 15 different critical system fields which currently show on the file maintenance log. At [...]

8. Debit/Credit Card Fraud Detection

Activity – Member cards are compromised. Solution – Create a flexible system configuration for the credit union to specify conditions to monitor as noted in the following situations: Excessive PIN failure (add a counter to the login procedure) Excessive cash withdrawals or cash advances Members over the age of X have more than Y transactions [...]

9. FinCEN

Activity – Credit unions are required to extract the FinCEN report and visually compare the reported list of names to see if any members are on the list. To date this has been done manually using Member Inquiry. Solution – Pull the file into CU*BASE and automate a scan similar to the manner in which [...]

10. Identity Theft

Activity – Member has not had any debit card or credit card activity (primarily Visa) for an extended period of time. A sudden onslaught of transactions in extraordinarily large amounts are one clue that this is identity theft. This activity has the potential for both loss of the card and card information. With the stolen [...]