CRCM Online Exam Set 1 2026/2027 | Practice Questions, Answers
& Certification Prep
Q. The compliance professional discovered weaknesses in the loan origination department. The root
cause of the issue appears to be due to prior training. What should the compliance professional do
FIRST?
Confirm a regular training schedule for the board, management, and staff as well as for third-party
service providers where appropriate for their roles and responsibilities
Assess all employees on their knowledge and comprehension of all consumer compliance protection
laws and regulations
Ensure the appropriate training is current and complete and includes accurate information on products,
services, regulations, internal policies and procedures, and emerging issues
Review the department's previous training, policies, procedures, completion rate, and role
responsibilities - Correct answer✅✅ Ensure the appropriate training is current and complete and
includes accurate information on products, services, regulations, internal policies and procedures, and
emerging issues
If compliance weaknesses are due to inadequate prior training, then the training issues must be
resolved. This is most likely due to problems with the content of the training, rather than frequency or
delivery. Confirming a regular training schedule is a secondary concern to inadequate training content.
And if the prior training has already been identified as the root cause, then reviewing that prior training
or assessing all employees on their knowledge and comprehension are moot points.
Q. During a review of the last exam report, the compliance professional discovers that violations have
been cited with regard to requiring an applicant's spouse to guarantee the loan. The compliance
professional is asked to review the bank's draft response and respond. What is the BEST plan of action?
Develop a new procedure to receive the signatures or initials on a credit application showing the
applicant's intent to apply for joint credit; form a committee to review prior loans where the spouse was
required to guarantee the loan in error
Develop a new procedure to receive the signatures or initials on a joint financial statement showing the
applicant's intent to apply for joint credit; form a committee to review prior loans where the spouse was
required to guarantee the loan in error
Respond that this is common practice in the banking industry and for safety and soundness reasons, the
bank needs to require the spo - Correct answer✅✅ Develop a new procedure to receive the
,signatures or initials on a credit application showing the applicant's intent to apply for joint credit; form
a committee to review prior loans where the spouse was required to guarantee the loan in error
Q. Which of the following would be considered a potential finding for credit cards?
Account payments were credited on the date received
Account payoff quotes were good for five business days
An account was reported "past due" after 30 days of nonpayment
An account had a credit balance for more than 60 days - Correct answer✅✅ An account had a credit
balance for more than 60 days
According to Regulation Z, credit balances must be returned to the consumer in no more than seven
business days if requested by the consumer. A credit balance of more than 60 days has the potential to
be in violation of this provision; thus, it is a finding. Each of the other choices is not a finding, as there is
no potential regulatory violation in any of them.
Q. How should the status of regulatory changes (on track, delayed, etc.) be periodically reported in
accordance with the financial institution's compliance management program?
Only changes that are delayed should be reported and only to the impacted line of defense leadership
All changes, regardless of status, should be reported only to the line of defense leadership
All changes representing material risk should be reported to the senior leadership across all lines of
defense
No reporting is required outside of the compliance department - Correct answer✅✅ All changes
representing material risk should be reported to the senior leadership across all lines of defense
Regulatory changes are critical to the entire institution, not just selected individuals or departments, or
even lines of defense. This is relative depending on the particular change, of course, but generally
speaking, when periodically reporting the implementation of changes, those involving material risks
should be reported to senior leadership across all lines of defense. Limiting reporting to only delayed
issues is not enough, nor is reporting only within the compliance department.
Q. What should the compliance professional consider a risk when monitoring for compliance with the
Fair Credit Reporting Act (Regulations V and FF)?
Adverse action notices were sent to customers who were denied checking accounts
, Prescreened solicitations do not include an opt-out to be excluded from future screenings
Credit reports are pulled on business purpose loans where the applicant has personal liability
Firm offers of credit are to be made to qualified applicants without the applicants' prior permission -
Correct answer✅✅ Prescreened solicitations do not include an opt-out to be excluded from future
screenings
The Fair Credit Reporting Act requires prescreened solicitations to include appropriate opt-out language
in both short-form and long-form. The absence of this required language would be a violation of the
FCRA, and thus a risk to be identified when monitoring. Each of the other choices is a compliant action
taken under Regulations V and FF.
Q. A compliance professional has been tasked with preparing the lines of business for an important
regulatory change. Which step should be taken FIRST?
Draft job-specific training to be delivered to impacted lines of business
Identify impacted lines of business and develop a team of key stakeholders
Confirm readiness to implement revised guidance on the part of the bank's platform software provider
Research, review, and then provide a summary of the impact to the lines of business - Correct
answer✅✅ Research, review, and then provide a summary of the impact to the lines of business
Change management is an essential part of any well-run compliance management system and is an
expectation of the regulators. In order to become aware of any new or modified requirements, it is
necessary to identify the sources of new information and then research and review any new changes.
Providing a summary of changes is an important part of this process. Only then can the development of
training or confirmation of readiness occur. Once the new rules have been analyzed, then the
appropriate team of impacted lines of business is brought together.
Q. A compliance professional is responsible for gathering, compiling, and submitting quarterly reports to
the examiner. During the past two quarters, several key departments have been late or incomplete with
their submissions. What is the BEST course of action?
Purchase and provide gift cards to motivate the heads of the offending departments to submit their
reports on time
Include a memo with the quarterly report requesting that the examiners pay extra attention to the
offending departments during the next exam
Meet with the heads of the offending departments to understand why reports are late and incomplete,
and recommend that the departments provide monthly status updates
& Certification Prep
Q. The compliance professional discovered weaknesses in the loan origination department. The root
cause of the issue appears to be due to prior training. What should the compliance professional do
FIRST?
Confirm a regular training schedule for the board, management, and staff as well as for third-party
service providers where appropriate for their roles and responsibilities
Assess all employees on their knowledge and comprehension of all consumer compliance protection
laws and regulations
Ensure the appropriate training is current and complete and includes accurate information on products,
services, regulations, internal policies and procedures, and emerging issues
Review the department's previous training, policies, procedures, completion rate, and role
responsibilities - Correct answer✅✅ Ensure the appropriate training is current and complete and
includes accurate information on products, services, regulations, internal policies and procedures, and
emerging issues
If compliance weaknesses are due to inadequate prior training, then the training issues must be
resolved. This is most likely due to problems with the content of the training, rather than frequency or
delivery. Confirming a regular training schedule is a secondary concern to inadequate training content.
And if the prior training has already been identified as the root cause, then reviewing that prior training
or assessing all employees on their knowledge and comprehension are moot points.
Q. During a review of the last exam report, the compliance professional discovers that violations have
been cited with regard to requiring an applicant's spouse to guarantee the loan. The compliance
professional is asked to review the bank's draft response and respond. What is the BEST plan of action?
Develop a new procedure to receive the signatures or initials on a credit application showing the
applicant's intent to apply for joint credit; form a committee to review prior loans where the spouse was
required to guarantee the loan in error
Develop a new procedure to receive the signatures or initials on a joint financial statement showing the
applicant's intent to apply for joint credit; form a committee to review prior loans where the spouse was
required to guarantee the loan in error
Respond that this is common practice in the banking industry and for safety and soundness reasons, the
bank needs to require the spo - Correct answer✅✅ Develop a new procedure to receive the
,signatures or initials on a credit application showing the applicant's intent to apply for joint credit; form
a committee to review prior loans where the spouse was required to guarantee the loan in error
Q. Which of the following would be considered a potential finding for credit cards?
Account payments were credited on the date received
Account payoff quotes were good for five business days
An account was reported "past due" after 30 days of nonpayment
An account had a credit balance for more than 60 days - Correct answer✅✅ An account had a credit
balance for more than 60 days
According to Regulation Z, credit balances must be returned to the consumer in no more than seven
business days if requested by the consumer. A credit balance of more than 60 days has the potential to
be in violation of this provision; thus, it is a finding. Each of the other choices is not a finding, as there is
no potential regulatory violation in any of them.
Q. How should the status of regulatory changes (on track, delayed, etc.) be periodically reported in
accordance with the financial institution's compliance management program?
Only changes that are delayed should be reported and only to the impacted line of defense leadership
All changes, regardless of status, should be reported only to the line of defense leadership
All changes representing material risk should be reported to the senior leadership across all lines of
defense
No reporting is required outside of the compliance department - Correct answer✅✅ All changes
representing material risk should be reported to the senior leadership across all lines of defense
Regulatory changes are critical to the entire institution, not just selected individuals or departments, or
even lines of defense. This is relative depending on the particular change, of course, but generally
speaking, when periodically reporting the implementation of changes, those involving material risks
should be reported to senior leadership across all lines of defense. Limiting reporting to only delayed
issues is not enough, nor is reporting only within the compliance department.
Q. What should the compliance professional consider a risk when monitoring for compliance with the
Fair Credit Reporting Act (Regulations V and FF)?
Adverse action notices were sent to customers who were denied checking accounts
, Prescreened solicitations do not include an opt-out to be excluded from future screenings
Credit reports are pulled on business purpose loans where the applicant has personal liability
Firm offers of credit are to be made to qualified applicants without the applicants' prior permission -
Correct answer✅✅ Prescreened solicitations do not include an opt-out to be excluded from future
screenings
The Fair Credit Reporting Act requires prescreened solicitations to include appropriate opt-out language
in both short-form and long-form. The absence of this required language would be a violation of the
FCRA, and thus a risk to be identified when monitoring. Each of the other choices is a compliant action
taken under Regulations V and FF.
Q. A compliance professional has been tasked with preparing the lines of business for an important
regulatory change. Which step should be taken FIRST?
Draft job-specific training to be delivered to impacted lines of business
Identify impacted lines of business and develop a team of key stakeholders
Confirm readiness to implement revised guidance on the part of the bank's platform software provider
Research, review, and then provide a summary of the impact to the lines of business - Correct
answer✅✅ Research, review, and then provide a summary of the impact to the lines of business
Change management is an essential part of any well-run compliance management system and is an
expectation of the regulators. In order to become aware of any new or modified requirements, it is
necessary to identify the sources of new information and then research and review any new changes.
Providing a summary of changes is an important part of this process. Only then can the development of
training or confirmation of readiness occur. Once the new rules have been analyzed, then the
appropriate team of impacted lines of business is brought together.
Q. A compliance professional is responsible for gathering, compiling, and submitting quarterly reports to
the examiner. During the past two quarters, several key departments have been late or incomplete with
their submissions. What is the BEST course of action?
Purchase and provide gift cards to motivate the heads of the offending departments to submit their
reports on time
Include a memo with the quarterly report requesting that the examiners pay extra attention to the
offending departments during the next exam
Meet with the heads of the offending departments to understand why reports are late and incomplete,
and recommend that the departments provide monthly status updates
