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FDIC guidance lists three requirements to ensure compliance with spousal signature rules include all of the following EXCEPT:

A.
Review and revise policies Eliminate policies or procedures that are inconsistent with the requirements Expand loan policies and procedures to provide loan staff with specific guidance on state law(s) regarding requiring signatures Cover the laws of all states where the creditor institution does business Create checklists to address situations when spousal signatures can be required
A.
Review and revise policies Eliminate policies or procedures that are inconsistent with the requirements Expand loan policies and procedures to provide loan staff with specific guidance on state law(s) regarding requiring signatures Cover the laws of all states where the creditor institution does business Create checklists to address situations when spousal signatures can be required
Answers
B.
Provide training to consumer and commercial loan staff
B.
Provide training to consumer and commercial loan staff
Answers
C.
Implement monitoring and auditing programs to check for spousal signature violations
C.
Implement monitoring and auditing programs to check for spousal signature violations
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D.
Must allow an applicant to designate a birth-given first name and a birth-given, surname, spouse's surname, or combination
D.
Must allow an applicant to designate a birth-given first name and a birth-given, surname, spouse's surname, or combination
Answers
Suggested answer: D

Content of notification to credit consumers must contain:

A.
Statement of the action taken
A.
Statement of the action taken
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B.
Name and address of creditor
B.
Name and address of creditor
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C.
Statement of the specific reasons for the adverse action or a disclosure of the applicant's right to receive the specific reasons within 30 days of a request. The request for specific reasons must be made within 60 days of the receipt of the adverse action notice.
C.
Statement of the specific reasons for the adverse action or a disclosure of the applicant's right to receive the specific reasons within 30 days of a request. The request for specific reasons must be made within 60 days of the receipt of the adverse action notice.
Answers
D.
Statement of the specific reasons for the adverse action or a disclosure of the applicant's right to receive the specific reasons within 15 days of a request. The request for specific reasons must be made within 30 days of the receipt of the adverse action notice.
D.
Statement of the specific reasons for the adverse action or a disclosure of the applicant's right to receive the specific reasons within 15 days of a request. The request for specific reasons must be made within 30 days of the receipt of the adverse action notice.
Answers
Suggested answer: A, B, C

A bank may engage in voluntary self-testing and self-correction of its compliance with Regulation B . If the bank takes any appropriate corrective action, the reports, results, analysis, opinions, and conclusions of the self-test will be protected by a privilege. The privilege will be lost if

A.
Loan and application files or other records related to a credit transaction and information derived from such files and records, even if it has been reorganized and summarized for analysis
A.
Loan and application files or other records related to a credit transaction and information derived from such files and records, even if it has been reorganized and summarized for analysis
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B.
The information is voluntarily disclosed to the government
B.
The information is voluntarily disclosed to the government
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C.
The public or is used in any manner as a defense to a discrimination charge
C.
The public or is used in any manner as a defense to a discrimination charge
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D.
credit information is furnished in response to inquiries concerning an account reflecting the participation of consumer
D.
credit information is furnished in response to inquiries concerning an account reflecting the participation of consumer
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Suggested answer: B, C

Creditors must retain for 25 months after the date that an offer of credit is made (12 months for business applicants with gross revenues of $1 million or less) the following items EXCEPT:

A.
The text of any prescreened solicitation
A.
The text of any prescreened solicitation
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B.
All other written information concerning the applicant
B.
All other written information concerning the applicant
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C.
The list of criteria used to select recipients
C.
The list of criteria used to select recipients
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D.
Any record of complaints regarding the solicitation
D.
Any record of complaints regarding the solicitation
Answers
Suggested answer: B

According to FDIC Guidance on Spousal Signature Provisions, if the creditor requires the spouse's signature on an instrument that imposes personal liability, the creditor's belief should be:

A.
Supported by a thorough review of pertinent statutes, decisional law, or an opinion of the state's attorney general
A.
Supported by a thorough review of pertinent statutes, decisional law, or an opinion of the state's attorney general
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B.
Supported by a thorough review of pertinent statutes
B.
Supported by a thorough review of pertinent statutes
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C.
Supported by decisional law
C.
Supported by decisional law
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D.
Supported by an opinion of the state's attorney general
D.
Supported by an opinion of the state's attorney general
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Suggested answer: A

A consumer reporting agency may furnish a consumer report

A.
If not authorized in writing by the consumer
A.
If not authorized in writing by the consumer
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B.
In response to a court order having jurisdiction or a subpoena issued by a federal grand jury or review or collection of an account of the consumer
B.
In response to a court order having jurisdiction or a subpoena issued by a federal grand jury or review or collection of an account of the consumer
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C.
In connection with a credit or insurance transaction
C.
In connection with a credit or insurance transaction
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D.
For employment purposes Before procuring a consumer report, an employer Must disclose to the individual in writing that a consumer report may be obtained Must obtain written authorization from the individual before procuring the report
D.
For employment purposes Before procuring a consumer report, an employer Must disclose to the individual in writing that a consumer report may be obtained Must obtain written authorization from the individual before procuring the report
Answers
Suggested answer: B, C, D

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?

A.
Read the law and write a new real estate compliance policy
A.
Read the law and write a new real estate compliance policy
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B.
Form a task force of the business unit managers whose departments will be affected by the law to collectively form an action plan
B.
Form a task force of the business unit managers whose departments will be affected by the law to collectively form an action plan
Answers
C.
Talk to the bank president about the need for more resources in compliance
C.
Talk to the bank president about the need for more resources in compliance
Answers
D.
Sign up all bank personnel affected by the changes for a seminar on the new law
D.
Sign up all bank personnel affected by the changes for a seminar on the new law
Answers
Suggested answer: B

A bank's president would like to begin offering a new home equity line of credit product within two weeks. In all cases the borrower's principal dwelling will secure the loan. The president has already launched a planned advertising campaign for the bank's major service markets. What should the compliance professional do FIRST?

A.
Hire an attorney to write the appropriate legal documents and disclosures
A.
Hire an attorney to write the appropriate legal documents and disclosures
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B.
Write a memo to the president explaining why the compliance professional should have been in on the process at an earlier date
B.
Write a memo to the president explaining why the compliance professional should have been in on the process at an earlier date
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C.
Begin training sessions for the lending and loan operations staff on the compliance issues involved
C.
Begin training sessions for the lending and loan operations staff on the compliance issues involved
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D.
Perform a risk assessment to determine the bank's level of risk in offering this new product
D.
Perform a risk assessment to determine the bank's level of risk in offering this new product
Answers
Suggested answer: D

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 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 department unit to purchase the software
A.
Elevate the issue to a higher authority to force the mortgage department unit to purchase the software
Answers
B.
Nothing; the compliance professional's job is done with the completed research
B.
Nothing; the compliance professional's job is done with the completed research
Answers
C.
Document the fact that the level of risk present with manual systems is acceptable to the mortgage department business unit
C.
Document the fact that the level of risk present with manual systems is acceptable to the mortgage department business unit
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D.
Write a memo to the president of the bank that explains the risk assessment for this area
D.
Write a memo to the president of the bank that explains the risk assessment for this area
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Suggested answer: C

The federal banking agencies have proposed an amendment to Regulation Z that would require a new early disclosure statement for loans secured by the borrower's principal dwelling. After reading the proposed change, what should the compliance professional do FIRST?

A.
Establish a task force to study the proposed rule.
A.
Establish a task force to study the proposed rule.
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B.
Contact the bank's platform software vendor to determine whether it will be ready for the change NOTES
B.
Contact the bank's platform software vendor to determine whether it will be ready for the change NOTES
Answers
C.
Prepare a summary document that outlines the effects the proposed rule would have on the bank's operations
C.
Prepare a summary document that outlines the effects the proposed rule would have on the bank's operations
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D.
Train bank staff on the new rule
D.
Train bank staff on the new rule
Answers
Suggested answer: C
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