Who is on the FDIC Board? Correct Answer - 1. Comptroller of the
Currency
2. Director of the CFPB
3. 3 appointed by President of US (incl. Chairmen)
a. Individuals who are citizens of US
b. One who shall have State bank
supervisory experience
Not more than three members may be of the same political party
6 yr term / 5 yr. for Chairman
Primary Causes of Violations Correct Answer - MUNW
Unfamiliarity
Negligence
Misinterpretation
Willful noncompliance
Bank may accept appraisal prepared by an appraiser engaged by another
bank, if..... Correct Answer - 1. Appraiser has no direct or indirect
interest in property/transaction
2. The regulated institution determines that the appriasal conforms to
requirements of Part 323 and is acceptable (Appraisal review)
What is the one fundamental & essential attribute all bank directors must
possess without exception? Correct Answer - Personal Integrity
What does Appendix B to Part 365 do? Correct Answer - Implement
Secure & Fair Enforcement for Mortgage Licensing Act's (SAFE Act)
registration requirement for mortgage loan originators
SAFE ACt provides (ATCAH)
Aggregating and improving the flow of information between regulators
Providing increased accountability and tracking of mortgage loan originators
Enhancing Consumer Protections
Supporting anti-fraud measures
Provide consumers employment history, disciplinary history, free and easily
accessible
, What should bank management do if they are asked to disclose a SAR through
subpoena or otherwise? (PART 353.3) Correct Answer - Decline to
produce SAR or any info that would disclose that SAR has been prepared or
filed using Part 353 as support and notify FDIC RO
Bank encouraged to file copies of SARs with appropriate State and local
authorities when appropriate
How long must a bank maintain copies of field SARs & supporting info? (Part
353.3) Correct Answer - 5 years from date of filing (and property of US
government).
Timelines for SAR filings? (Part 353.3) Correct Answer - A SAR must be
filed within 30 days of initial detection of facts warranting SAR
If no suspect identified - timeline can be extended to 60 days.
When does a bank not have to file a SAR? Correct Answer - Robbery or
burglary reported to law enforcement
Lost, missing, counterfeit, or stolen securities if following proper reporting
requirements to SEC.
When must a bank file a SAR? Correct Answer - 1. Insider abuse
involving any amount - directors, officers, employees, agents, or other IAPs
2. Suspected federal criminal violations of $5M or more where a suspect can
be identified.
3. Suspected federal criminal violations of $25M+ w/o ID of suspect
4. Transactions aggregating $5M or more that involve potential money
laundering or Vios of BSA.
How does FDIC enforce Part 348? (Management Interlock) Correct Answer
- Refers case to the Attorney General to ensure compliance with Interlocks
Act