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CRCM Questions and Answers (100% Correct
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A bank has a large mortgage department as well as a high HMDA error
rate. An expensive software program could automate the process, but
the business unit manager does not want to purchase the software
because of its expense. Though it is not as efficient, the manager prefers
to make some improvements to the manual process, add some more
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robust monitoring procedures, and opt not to purchase the software.
What should the compliance professional do?
A. Elevate the issue to a higher authority to force the mortgage
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department unit to purchase the software
B. Nothing; the compliance professional's job is done with the completed
research
C. Document the fact that the level of risk present with manual systems is
acceptable to the mortgage department business unit
D. Write a memo to the president of the bank that explains the risk
assessment for this area Ans: The correct answer is c. Outline
introduction and II B(2)
The job of the compliance officer is to assess the risks and inform
management of those risks. The business unit can decide what level of
risk to accept. If the high level of HMDA errors continues, even with the
improved procedures, the problem can be escalated and brought to
senior management's attention.
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During a recent compliance examination, regulatory examiners found
that the bank was not conducting flood hazard area determinations
before closing on construction loans. The compliance professional has
reviewed the files and agreed with the examiners' finding. What should
be done FIRST?
A. Review the bank's flood policies and procedures to determine where
the compliance failure occurred
B. Conduct a risk assessment of the flood determination requirement on
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construction loans
C. Prepare an analysis for bank management explaining the
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requirement
D. Review all construction loan files to determine the extent of the
problem Ans: The correct answer is a. Outline II D
If the compliance professional agrees with the regulators on a finding,
the root cause of the error must be determined by consulting policies
and procedures. There is no benefit to conducting a risk assessment
because the issue is known. After determining the cause, then the extent
of the problem must be determined. Only after gathering this pertinent
information can the compliance professional write an analysis for
management explaining the situation.
A compliance professional is a member of the task force studying how
the bank can reduce customer complaints about holding deposits. One
proposed solution involves purchasing an expensive system that will
reduce the number of holds placed by evaluating the customer's history
and relationship with the bank. Which of the following roles is MOST
important for the compliance professional on the task force?
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A. Developing training for tellers who will use the new system
B. Setting parameters for what the system should review to determine the
strength of the customer relationship
C. Validating the system to ensure it complies with regulatory restrictions
D. Conducting a cost-benefit analysis to determine if the system is the
best solution Ans: The correct answer is c. Outline III D
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The compliance professional's role on a task force is to provide
knowledge about compliance risk, such as whether the system is in
compliance with relevant laws and regulations. The training, parameters,
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and cost-benefit analysis are more operational in nature.
When developing a training plan for commercial lenders, which of the
following regulations is least important to include?
A. Equal Credit Opportunity, CFPB Regulation B
B. Home Mortgage Disclosure, CFPB Regulation C
C. Loans to Executive Officers, Directors, and Principal Shareholders of
Member Banks, FRS Regulation O
D. Truth in Lending Act, CFPB Regulation Z Ans: The correct answer is d.
Outline II E(2)(a)
The compliance professional should risk manage the training program. A
commercial group needs to know the rules for fair lending, HMDA, and
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insider lending. Regulation Z is more relevant for the consumer lending
audience.
During a recent compliance examination, regulators cited the bank for
violations of various marketing regulations. How should the compliance
professional FIRST respond?
A. Contact the bank's marketing manager to discuss the finding
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B. Develop a policy requiring that all marketing materials be reviewed
and approved by compliance before being published
C. Set up a training class for the marketing department
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D. Review the marketing materials and applicable regulations to verify
the finding. Ans: The correct answer is d. Outline II D(3)
When a bank is cited for a regulatory violation, the compliance
professional must first determine whether the bank should agree with it.
This is done by reviewing the pertinent regulations and affected
materials. If the citation is supported by the regulations, then the
compliance manager should discuss it with the marketing manager.
Solutions may include training marketing personnel or establishing new
policies for reviews.
Legislation was recently enacted to reform consumer real estate
protection laws, and the bank will now have to change the way it
documents, discloses, and advertises real estate loans, an integral
product line at your bank. What should the compliance professional do
FIRST to implement the new law within the bank?