Completion of the Red Flag Questionnaire for Small Credit Unions became a requirement on
April 1, 2009, based on a memo issued by NCUA’s Office of Examination and Insurance,
dated March 12, 2009. At the time of Taupa’s failure, NCUA defined small credit unions as
those with assets of $10 million or less,
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a requirement that only applied to federally
chartered credit unions, so it did not apply to Taupa, a state-chartered credit union with assets
of approximately $23 million. However, prudent business practices do not limit fraud
considerations to asset size. The fact that Taupa’s fraud exceeded its asset size gives
credence to this practice