CRCM EXAM 2025 QUESTIONS AND
ANSWERS
Which of the following is not exempt from the rules on reasonable and proportional pricing of
electronic debit transactions? - ANS A debit card issued by a community bank with $7 billion
in assets, affiliated with another depository institution with assets of $5 billion
Which of the following statements is true regarding debt card interchange fees and routing? -
ANS An issuer can meet the requirements of the network exclusivity rule by allowing
transactions to be processed on two unaffiliated payment card networks that don't restrict
transactions based on geography, merchant or transaction type.
In order to qualify for the fraud prevention adjustment an issuer must (debt card interchange
fees and routing): - ANS Implement fraud prevention and detection policies
ABC Bank has several customers with hearing disabilities. Of the following, which statement is
true? - ANS The bank must reasonably provide auxiliary aids and services to assist in
communications with its disabled customers
Which of the following activities is permitted under ADA? - ANS Prohibiting smoking
anywhere in the bank building - The bank cannot discriminate against persons who regularly
associate with persons with disabilities. It also cannot charge for auxiliary devices that are used
as a reasonable accommodation. Therefore, it cannot charge for the readers. The bank may not
force a disabled person to use a segregated service, such as a special teller window. If the
disabled person wants to use the regular window, the bank must allow him or her to do so. The
bank may prohibit smoking within the building.
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
1
,Bank A offers safe deposit services in a vault area that contains a door too narrow for
wheelchair passage. The bank cannot widen the door because of the vault construction.
Therefore, when a customer in a wheelchair needs access to a safe deposit box the customer
cannot enter the vault. The bank provides viewing rooms for all safe deposit customers, and
one of these rooms has a door wide enough for a disabled customer to enter. Which of the
following must the bank do to provide safe deposit box service to wheelchair customers? -
ANS Bring the safe deposit box to the customer and provide an accessible area where the
customer may privately have access to the contents - The bank must make this service available
in a manner that provides equal benefits. Because a nondisabled person would not have to be
accompanied by another individual, the bank cannot require this of a disabled person. Also, the
construction of a new vault is a significantly expensive undertaking, one that would probably
impose an undue burden on the bank. The best alternative is to provide the disabled person
with access to a private location and have bank personnel retrieve and deliver the box.
The mortgage lending department of Bank XYZ received some inquiries from potential
applicants who are visually impaired. The bank would like to comply with ADA concerning these
potential applicants, but it does not want to spend a significant amount of money. Which of the
following statements is true? - ANS The bank may have a loan assistant read each loan
application and disclosure document to the applicant and assist in completion of the forms. -
Although the bank may have its documents translated into Braille, it is not required to do so.
The bank cannot require that the applicant bring a nondisabled friend, and it cannot make a
policy that blatantly discriminates against a class of disabled persons.
Bob's wife is HIV-positive due to a blood transfusion during an appendectomy 15 years ago. She
is not yet sick, but takes medication to prevent the onset of AIDS. Bob occasionally needs to
take time off from work to take her for testing at Johns Hopkins in Baltimore. Because of
complaints about Bob's exposure to this disease, employees have asked HR to limit his contact
with them and with customers. The bank has asked Bob not to eat in the lunchroom with the
other employees and has placed Bob in a position where he has limited customer contact. Does
this company have any potential ADA liability? - ANS Yes. Because the manager has
associated Bob with this disease, the ''associated with'' rule applies
Which of the following employment practices is NOT legal under ADA? - ANS Establishing a
policy that prohibits hiring alcoholic applicants - The bank may establish a policy that prohibits
hiring applicants (or permits the firing of employees) who are under the influence of alcohol
while at work. Because alcoholism is a disability, the bank cannot have a policy of refusing to
hire such persons. However, the bank may hold the employee to the same performance
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
2
,standards and rules, (including those against being under the influence of alcohol at work) as
the other employees.
Under the ADA, what can an employer do? - ANS Inquire about a disability when offering a
job provided the disability is related to the job requirements - The employer may inquire about
a disability that is related to the job function. If necessary, the employer must provide a
reasonable accommodation so that the employee can perform the necessary job functions.
Mills Company, Inc., is a manufacturing company with a working capital line of credit from First
National Bank. The credit agreement governing the loan states that Mills cannot obtain
additional unsecured credit without the approval of the bank. Mills believes that such a clause
violates the Bank Holding Company Act's anti-tying clause. Does it? - ANS No, since this
clause relates to the soundness of the credit - Banks may not extend credit, lease or sell
property, furnish services, fix, or vary consideration conditioned on the customer not obtaining
credit or services from a bank competitor unless imposed to assure soundness of the credit.
Roger Jameson is the head of the consumer loan department at First National Bank. He is a
regular participant in a lending committee of a local finance trade association. The committee
meets once a month at a local hotel. After the committee meetings, Roger and several other
committee members who are officers at other banks in town go to a hotel restaurant and talk
for a couple of hours before leaving. During these informal conversations Roger learned that
the other members require the car dealerships in town that sell consumer installment contracts
to the banks to refrain from selling them to local savings and loan associations. Roger believes
that this is a good idea and would like to implement it at First National. Is there a problem with
doing so? - ANS Yes. Restricting the dealerships is a restraint of trade. - This action could be
considered both a restraint of trade and a conspiracy to restrain trade.
First National is developing a consumer checking account that can access a line of credit. This is
the first time the bank has ever had such a product, although this type of credit facility has been
popular with other banks in town. To determine what interest rate to charge on this account,
an officer of First National called some of his friends at other local banks offering this type of
credit and asked several questions, including the interest rate charged on this type of account
and what internal factors the banks use to set the rate. After obtaining this information, First
National determines that it could charge approximately 2 percent more than it originally
planned. Is there anything wrong with this course of action? - ANS Yes. Communicating with
competitors for purposes of setting prices is wrong. - This scenario is an antitrust price-setting
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
3
, problem. The bank is blatantly attempting to lessen competition by setting prices based on the
prices of competitors. The whole purpose of the antitrust laws is to prevent this type of price
setting.
First National Bank owns a data processing company that sells financially related data
processing services to various businesses in the community. Daniel Tyler, a loan officer, is
negotiating a loan to a local CPA firm. He would like to make the loan conditional on the CPA
firm's use of the subsidiary data processing firm. May he do so? - ANS No. It is an illegal tie-
in. - No loan can be conditioned on the borrower obtaining services from a bank subsidiary.
Martha Smith of First National Bank is attempting to close a large commercial loan to a
manufacturing equipment company. In negotiating the interest rate on the loan Martha states
that if the company will move some of its demand accounts to the bank, it could get a lower
interest rate. Is this wrong? - ANS No. The bank may condition the loan on the customer
placing a deposit in the bank. - The bank may condition the extension of a loan on the customer
placing a deposit in the bank. Anti-tying provisions stipulate that banks may not extend credit,
lease or sell property, furnish services, fix, or vary consideration conditioned on the customer
obtaining additional credit or service from the bank other than a loan, discount, deposit, or
trust service.
For which of the following business activities must a bank holding company obtain prior
approval of the Federal Reserve Board? - ANS Operating an auto club service
Which of the following activities is NOT a permissible nonbanking activity? - ANS Providing
general courier services to the businesses around the bank office - Courier services may only be
provided for banking and other financial records.
Which of the following is NOT a factor considered by the Federal Reserve Board when it
evaluates an application under Regulation Y? - ANS The current nonbanking activities of the
applicant. The Fed DOES consider the following: (1) The financial strength of the applicant, (2)
The management strength of the applicant, and (3) The effect of the transaction on
competition.
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
4
ANSWERS
Which of the following is not exempt from the rules on reasonable and proportional pricing of
electronic debit transactions? - ANS A debit card issued by a community bank with $7 billion
in assets, affiliated with another depository institution with assets of $5 billion
Which of the following statements is true regarding debt card interchange fees and routing? -
ANS An issuer can meet the requirements of the network exclusivity rule by allowing
transactions to be processed on two unaffiliated payment card networks that don't restrict
transactions based on geography, merchant or transaction type.
In order to qualify for the fraud prevention adjustment an issuer must (debt card interchange
fees and routing): - ANS Implement fraud prevention and detection policies
ABC Bank has several customers with hearing disabilities. Of the following, which statement is
true? - ANS The bank must reasonably provide auxiliary aids and services to assist in
communications with its disabled customers
Which of the following activities is permitted under ADA? - ANS Prohibiting smoking
anywhere in the bank building - The bank cannot discriminate against persons who regularly
associate with persons with disabilities. It also cannot charge for auxiliary devices that are used
as a reasonable accommodation. Therefore, it cannot charge for the readers. The bank may not
force a disabled person to use a segregated service, such as a special teller window. If the
disabled person wants to use the regular window, the bank must allow him or her to do so. The
bank may prohibit smoking within the building.
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
1
,Bank A offers safe deposit services in a vault area that contains a door too narrow for
wheelchair passage. The bank cannot widen the door because of the vault construction.
Therefore, when a customer in a wheelchair needs access to a safe deposit box the customer
cannot enter the vault. The bank provides viewing rooms for all safe deposit customers, and
one of these rooms has a door wide enough for a disabled customer to enter. Which of the
following must the bank do to provide safe deposit box service to wheelchair customers? -
ANS Bring the safe deposit box to the customer and provide an accessible area where the
customer may privately have access to the contents - The bank must make this service available
in a manner that provides equal benefits. Because a nondisabled person would not have to be
accompanied by another individual, the bank cannot require this of a disabled person. Also, the
construction of a new vault is a significantly expensive undertaking, one that would probably
impose an undue burden on the bank. The best alternative is to provide the disabled person
with access to a private location and have bank personnel retrieve and deliver the box.
The mortgage lending department of Bank XYZ received some inquiries from potential
applicants who are visually impaired. The bank would like to comply with ADA concerning these
potential applicants, but it does not want to spend a significant amount of money. Which of the
following statements is true? - ANS The bank may have a loan assistant read each loan
application and disclosure document to the applicant and assist in completion of the forms. -
Although the bank may have its documents translated into Braille, it is not required to do so.
The bank cannot require that the applicant bring a nondisabled friend, and it cannot make a
policy that blatantly discriminates against a class of disabled persons.
Bob's wife is HIV-positive due to a blood transfusion during an appendectomy 15 years ago. She
is not yet sick, but takes medication to prevent the onset of AIDS. Bob occasionally needs to
take time off from work to take her for testing at Johns Hopkins in Baltimore. Because of
complaints about Bob's exposure to this disease, employees have asked HR to limit his contact
with them and with customers. The bank has asked Bob not to eat in the lunchroom with the
other employees and has placed Bob in a position where he has limited customer contact. Does
this company have any potential ADA liability? - ANS Yes. Because the manager has
associated Bob with this disease, the ''associated with'' rule applies
Which of the following employment practices is NOT legal under ADA? - ANS Establishing a
policy that prohibits hiring alcoholic applicants - The bank may establish a policy that prohibits
hiring applicants (or permits the firing of employees) who are under the influence of alcohol
while at work. Because alcoholism is a disability, the bank cannot have a policy of refusing to
hire such persons. However, the bank may hold the employee to the same performance
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
2
,standards and rules, (including those against being under the influence of alcohol at work) as
the other employees.
Under the ADA, what can an employer do? - ANS Inquire about a disability when offering a
job provided the disability is related to the job requirements - The employer may inquire about
a disability that is related to the job function. If necessary, the employer must provide a
reasonable accommodation so that the employee can perform the necessary job functions.
Mills Company, Inc., is a manufacturing company with a working capital line of credit from First
National Bank. The credit agreement governing the loan states that Mills cannot obtain
additional unsecured credit without the approval of the bank. Mills believes that such a clause
violates the Bank Holding Company Act's anti-tying clause. Does it? - ANS No, since this
clause relates to the soundness of the credit - Banks may not extend credit, lease or sell
property, furnish services, fix, or vary consideration conditioned on the customer not obtaining
credit or services from a bank competitor unless imposed to assure soundness of the credit.
Roger Jameson is the head of the consumer loan department at First National Bank. He is a
regular participant in a lending committee of a local finance trade association. The committee
meets once a month at a local hotel. After the committee meetings, Roger and several other
committee members who are officers at other banks in town go to a hotel restaurant and talk
for a couple of hours before leaving. During these informal conversations Roger learned that
the other members require the car dealerships in town that sell consumer installment contracts
to the banks to refrain from selling them to local savings and loan associations. Roger believes
that this is a good idea and would like to implement it at First National. Is there a problem with
doing so? - ANS Yes. Restricting the dealerships is a restraint of trade. - This action could be
considered both a restraint of trade and a conspiracy to restrain trade.
First National is developing a consumer checking account that can access a line of credit. This is
the first time the bank has ever had such a product, although this type of credit facility has been
popular with other banks in town. To determine what interest rate to charge on this account,
an officer of First National called some of his friends at other local banks offering this type of
credit and asked several questions, including the interest rate charged on this type of account
and what internal factors the banks use to set the rate. After obtaining this information, First
National determines that it could charge approximately 2 percent more than it originally
planned. Is there anything wrong with this course of action? - ANS Yes. Communicating with
competitors for purposes of setting prices is wrong. - This scenario is an antitrust price-setting
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
3
, problem. The bank is blatantly attempting to lessen competition by setting prices based on the
prices of competitors. The whole purpose of the antitrust laws is to prevent this type of price
setting.
First National Bank owns a data processing company that sells financially related data
processing services to various businesses in the community. Daniel Tyler, a loan officer, is
negotiating a loan to a local CPA firm. He would like to make the loan conditional on the CPA
firm's use of the subsidiary data processing firm. May he do so? - ANS No. It is an illegal tie-
in. - No loan can be conditioned on the borrower obtaining services from a bank subsidiary.
Martha Smith of First National Bank is attempting to close a large commercial loan to a
manufacturing equipment company. In negotiating the interest rate on the loan Martha states
that if the company will move some of its demand accounts to the bank, it could get a lower
interest rate. Is this wrong? - ANS No. The bank may condition the loan on the customer
placing a deposit in the bank. - The bank may condition the extension of a loan on the customer
placing a deposit in the bank. Anti-tying provisions stipulate that banks may not extend credit,
lease or sell property, furnish services, fix, or vary consideration conditioned on the customer
obtaining additional credit or service from the bank other than a loan, discount, deposit, or
trust service.
For which of the following business activities must a bank holding company obtain prior
approval of the Federal Reserve Board? - ANS Operating an auto club service
Which of the following activities is NOT a permissible nonbanking activity? - ANS Providing
general courier services to the businesses around the bank office - Courier services may only be
provided for banking and other financial records.
Which of the following is NOT a factor considered by the Federal Reserve Board when it
evaluates an application under Regulation Y? - ANS The current nonbanking activities of the
applicant. The Fed DOES consider the following: (1) The financial strength of the applicant, (2)
The management strength of the applicant, and (3) The effect of the transaction on
competition.
COPYRIGHT © 2025 THESTAR ALL RIGHTS RESERVED
4
