SANFORD, Maine-BSA compliance was out of reach for York County FCU here-the process was so "overwhelming" that some activities fell through the cracks, said Peggy Gilman, VP-operations at the $190-million CU.

"We did everything manually," based on a Bank Secrecy Act (BSA) policy template purchased online, Gilman explained. "I was following an FFIEC manual and hoping I got it right. I spent a week every year preparing and reviewing the policy and then following up with staff to make sure each task was accomplished. Compliance was almost like a line of business for us."

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