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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
A.
Review the bank's flood policies and procedures to determine where the compliance failure occurred
Answers
B.
Conduct a risk assessment of the flood determination requirement on construction loans
B.
Conduct a risk assessment of the flood determination requirement on construction loans
Answers
C.
Prepare an analysis for bank management explaining the requirement
C.
Prepare an analysis for bank management explaining the requirement
Answers
D.
Review all construction loan files to determine the extent of the problem
D.
Review all construction loan files to determine the extent of the problem
Answers
Suggested answer: A

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
A.
Contact the bank's marketing manager to discuss the finding
Answers
B.
Develop a policy requiring that all marketing materials be reviewed and approved by compliance before being published
B.
Develop a policy requiring that all marketing materials be reviewed and approved by compliance before being published
Answers
C.
Set up a training class for the marketing department
C.
Set up a training class for the marketing department
Answers
D.
Review the marketing materials and applicable regulations to verify the finding.
D.
Review the marketing materials and applicable regulations to verify the finding.
Answers
Suggested answer: D

When developing a training plan for commercial lenders, which of the following regulations is least important to include?

A.
Equal Credit Opportunity, FRS Regulation B
A.
Equal Credit Opportunity, FRS Regulation B
Answers
B.
Home Mortgage Disclosure, FRS Regulation C
B.
Home Mortgage Disclosure, FRS Regulation C
Answers
C.
Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks, FRS Regulation O
C.
Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks, FRS Regulation O
Answers
D.
Truth in Lending Act, FRS Regulation Z
D.
Truth in Lending Act, FRS Regulation Z
Answers
Suggested answer: D

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?

A.
Developing training for tellers who will use the new system
A.
Developing training for tellers who will use the new system
Answers
B.
Setting parameters for what the system should review to determine the strength of the customer relationship
B.
Setting parameters for what the system should review to determine the strength of the customer relationship
Answers
C.
Validating the system to ensure it complies with regulatory restrictions
C.
Validating the system to ensure it complies with regulatory restrictions
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D.
Conducting a cost-benefit analysis to determine if the system is the best solution
D.
Conducting a cost-benefit analysis to determine if the system is the best solution
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Suggested answer: C

Of the following loans made by a national bank, which loan is NOT covered by the OCC ARM regulation?

A.
A loan to purchase a single-family dwelling to be used as a residence, secured by the dwelling with an adjustable interest rate
A.
A loan to purchase a single-family dwelling to be used as a residence, secured by the dwelling with an adjustable interest rate
Answers
B.
A loan made to purchase a mobile home to be used as rental property, secured by the home with a variable interest rate
B.
A loan made to purchase a mobile home to be used as rental property, secured by the home with a variable interest rate
Answers
C.
A loan made to purchase an eight-unit apartment complex, secured by the building, made payable on demand with a variable rate of interest
C.
A loan made to purchase an eight-unit apartment complex, secured by the building, made payable on demand with a variable rate of interest
Answers
D.
A loan made to purchase a duplex, secured by the dwelling, amortized over 15 years with a 5-year maturity, at a variable rate of interest
D.
A loan made to purchase a duplex, secured by the dwelling, amortized over 15 years with a 5-year maturity, at a variable rate of interest
Answers
Suggested answer: C

First National Bank is a member of a multibank holding company. The bank makes ARM loans and occasionally purchases ARM loans from its affiliate national and state banks as well as from nonaffiliate banks. Which of the following practices is NOT acceptable under the OCC ARM regulation?

A.
The bank purchases loans from its state affiliate banks where the index on the loan is tied to First National's prime rate.
A.
The bank purchases loans from its state affiliate banks where the index on the loan is tied to First National's prime rate.
Answers
B.
The bank makes loans to purchase single-family dwellings with interest rates that may be adjusted from time to time.
B.
The bank makes loans to purchase single-family dwellings with interest rates that may be adjusted from time to time.
Answers
C.
The bank links the interest rate indices on its own ARM loans to them national prime rate as published in The Wall Street Journal.
C.
The bank links the interest rate indices on its own ARM loans to them national prime rate as published in The Wall Street Journal.
Answers
D.
The bank requires its national bank affiliates to use the national prime rate as published in The Wall Street Journal as the index for any of the ARM loans it purchases.
D.
The bank requires its national bank affiliates to use the national prime rate as published in The Wall Street Journal as the index for any of the ARM loans it purchases.
Answers
Suggested answer: A

On which of the following adjustable-rate loans must the bank use an index beyond its control?

A.
A loan to purchase a home to refurnish and resell for a profit
A.
A loan to purchase a home to refurnish and resell for a profit
Answers
B.
A loan to purchase a vacation home
B.
A loan to purchase a vacation home
Answers
C.
A loan to purchase a duplex where the borrower will live in one of the units
C.
A loan to purchase a duplex where the borrower will live in one of the units
Answers
D.
A loan to purchase a home to be used as rental property
D.
A loan to purchase a home to be used as rental property
Answers
Suggested answer: C

ABC National Bank regularly purchases mortgage loans from ACME Mortgage Company, a local mortgage broker. ACME places a mandatory arbitration clause in each of its mortgage documents. ACME believes this clause is necessary because of state laws governing arbitration. Is this clause a problem for ABC National?

A.
No, unless other predatory or abusive lending practices are evident in the loans sold by ACME.
A.
No, unless other predatory or abusive lending practices are evident in the loans sold by ACME.
Answers
B.
Yes, the clause is a sign of an abusive lender, and the bank should not purchase the loans.
B.
Yes, the clause is a sign of an abusive lender, and the bank should not purchase the loans.
Answers
C.
Yes, the bank should make ACME strike the clause from future loans.
C.
Yes, the bank should make ACME strike the clause from future loans.
Answers
D.
No, this is a common practice and the bank can ignore it.
D.
No, this is a common practice and the bank can ignore it.
Answers
Suggested answer: A

The OCC recommends all but one of the following actions to help prevent a national bank's purchasing or acquiring predatory or abusive loans. Which practice is NOT recommended?

A.
Establish policies on the bank's relationship with third-party brokers and originators
A.
Establish policies on the bank's relationship with third-party brokers and originators
Answers
B.
Review loan documentation
B.
Review loan documentation
Answers
C.
Audit the third-party broker
C.
Audit the third-party broker
Answers
D.
Require the broker to establish a reserve account for legal contingencies
D.
Require the broker to establish a reserve account for legal contingencies
Answers
Suggested answer: D

Second State Bank offers a mortgage product that involves simultaneous second lien loans. These include a first lien for up to 90 percent of the purchase price and a second loan for the down payment, secured by a second lien on the property. The bank would like to be in full compliance with the Interagency Guidance on Nontraditional Mortgage Product Risks. Which of the following should Second State Bank incorporate into its loan program?

A.
Risk management procedures to measure the risk of all simultaneous second lien loans and report results to management
A.
Risk management procedures to measure the risk of all simultaneous second lien loans and report results to management
Answers
B.
A 100 percent loan loss reserve on all simultaneous second lien loans
B.
A 100 percent loan loss reserve on all simultaneous second lien loans
Answers
C.
A product combining simultaneous second lien loans with negative amortization features made to nonowner occupied borrowers
C.
A product combining simultaneous second lien loans with negative amortization features made to nonowner occupied borrowers
Answers
D.
A prepayment penalty on all simultaneous second lien loans
D.
A prepayment penalty on all simultaneous second lien loans
Answers
Suggested answer: A
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