4501A Profile FAQs

An EIN is the Employer Identification Number issued by the IRS.

Report the settlement agent that processes the most transactions for the credit union.

There are both qualified and non-qualified pension plans.

Qualified plans are regulated by ERISA and have pension assets held off-balance sheet for the benefit of the participants. These plans are generally for the entire employee population with vesting requirements. They can also be over- or under-funded with those amounts going into Other Comprehensive Income. Over- and under-funding are actuarial calculations and are supposed to represent the financial status of the plan as a stand-alone entity. The assets in the plan are not part of the liquidation estate in the event of conservatorship. However, there have been cases where the Pension Benefit Guaranty Corporation has placed claims on liquidation estates, which has resulted in a cost to the Share Insurance Fund.

Non-qualified plans are for executives, commonly known as “top hat” plans. These plans are not regulated by ERISA and the assets are held on-balance sheet. The assets are part of a liquidation estate of a credit union and are at risk to the beneficiary.

Unlike the Call Report, prior Profile data cannot be changed. If something is incorrect in the Profile, change the incorrect information then Certify and Submit the Profile. This will correct the data going forward.

Double check to make sure that you added a zip code. The system uses a database from the US Postal Service to verify the address. Sometimes the address verification can fail because you did not enter the address exactly the way the Post Office has it on file. To check the address, go to www.usps.com and use the “Find a Zip Code” function to confirm your address.

Please email 5300@ncua.gov or call the NCUA Customer Support at 1.800.827.3255.

No. You should only identify individuals responsible for the Bank Secrecy Act and Customer Identification programs at the credit union.

For any Profile changes to take effect, you must first certify the Profile (if not certified, the information is considered draft). Once you update your Patriot Act Contact(s) and certify the Profile, it may take up to three weeks before the new or updated email addresses begin receiving FinCEN notifications.

Double check to make sure that you added a zip code. The system uses a database from the US Postal Service to verify the address. Sometimes the address verification can fail because you did not enter the address exactly the way the Post Office has it on file. To check the address, go to www.usps.com and use the “Find a Zip Code” function to confirm your address.

Yes, a credit union’s Disaster Recovery Center and Vital Records Center can have the same location. However, a P.O. Box is not an acceptable address for either the Disaster Recovery Center or the Vital Records Center.

No. NCUA Rules and Regulations Part 749 specifies the credit union must store vital records at a location far enough from the credit union’s office to avoid simultaneous loss of both sets of records in the case of a disaster.

No. If the form is available to print, but members must “physically” deliver it to the credit union, it is not an electronic service. This applies to member applications, new loans, and new share accounts.

No. A variety of media store electronic cash and the amount of cash available is stored on the card itself. Debit cards, credit cards and most gift cards rely on sending information over networks to a centralized server to determine if the amount of the transaction is available or not.

Transactional. The instructions indicate you should report based on the degree of information and/or services you offer online. You are providing online transactional services to your members via the third party.

Software as a Service (Saas): SaaS allows users to connect to and use cloud-based apps over the Internet. The majority of SaaS applications run directly through a web browser, which means they rarely require downloads or installations.

Infrastructure as a Service (IaaS): IaaS is a type of cloud computing service that offers essential compute, storage, and networking resources on demand, on a pay-as-you-go basis, as opposed to purchasing or leasing the hardware.

Platform as a service (PaaS): PaaS is a complete development and deployment environment located in the cloud, with resources enabling each customer to deliver everything from simple cloud-based applications to sophisticated, cloud-enabled enterprise applications and solutions.

On-premise: If the credit union maintains their email server in-house.

Cloud: If the institution relies upon a cloud provider for email services (an email solution hosted by a third party).

Hybrid: If the institution uses both an on-premise (in-house) solution as well as a hosted solution for communications.

No, NCUA only requires you to enter the most recent date for these Profile fields.

No. There are several acceptable ways to test a disaster recovery plan. You can find more information on acceptable testing methods in the FFIEC Business Continuity Planning Booklet.

Yes. Users can edit or delete information on the Regulatory page. If you are updating your profile to reflect a new annual meeting, financial statement audit, member account verification or disaster recovery date, you should add a new date, not edit the existing dates in the system. The edit and delete functions are intended for you to efficiently correct data entry errors.

The Profile Instructions say to report the maximum coverage your fidelity bond provides for any single loss. You fidelity bond provider may refer to this as blanket bond coverage or employee/director dishonesty coverage. Additional information on bond coverage can be found in NCUA regulations part 713.

No, investment services offered to members through the broker dealer would not be considered using a financial technology company.

No, the use of credit bureaus, market research companies, or ad agencies to receive leads or purchase mailing lists would not constitute the use of financial technology in lead generation.