Abnormal Activity Monitoring Transaction Patterns: A Guide for Change Management and Data Governance



The Transaction Pattern option within the Abnormal Activity Monitoring CU*BASE tool was developed to arm credit unions with a means to identify anomalous account activity daily. This booklet describes the change management and data governance methodology developed by AuditLink for use by our credit union partners

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What’s Inside

The FFIEC and CFPB are urging credit unions to identify and monitor high-risk activity amongst their member base. The transaction pattern option within the Abnormal Activity Monitoring CU*BASE tool was designed to assist credit unions with meeting that requirement. The patterns need to be configured specific to your credit union, because every credit union has a different membership composition. A well-tuned configuration is vital for achieving an efficient and effective abnormal activity identification and review process. It is also imperative to have a method for ensuring the integrity of the data being reviewed, that is, something to record the before-and-after of what a configuration was prior to it being changed. A documented basis for why a change was made is equally important.

When making adjustments, an important question to keep in mind is: “By changing this pattern, will previously flagged high-risk accounts no longer be identified?”

The booklet covers the following process.

  • Making Adjustments to the Default Configurations
  • Recording Configuration Changes
  • Reviewing Accounts to Determine False Positive Rate
  • Recording False Positive Rates
  • Recording Configuration Changes

Also included: Templates for making it all easy!

 Who Should Read This Booklet?

This booklet was written for the BSA compliance practitioner, from a practitioner’s perspective. Specifically, it is useful for the BSA Compliance Officer or designated personnel as a guide for adjusting transaction pattern configurations. Instead of identifying and reviewing accounts with normal activity, dial in your patterns to flag what is truly unusual.

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