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For example on a 0-5 scale:

The risk trend shows the direction of risk and probable change to risk over the next 12 months. A trend toward increasing risk means that

A.
Management may want to take additional action through more controls or increased reviews
A.
Management may want to take additional action through more controls or increased reviews
Answers
B.
Risk may prompt a decrease in controls and improved efficiencies
B.
Risk may prompt a decrease in controls and improved efficiencies
Answers
C.
Controls currently in place are appropriate to succeed in keeping risks within management's established risk-tolerance level
C.
Controls currently in place are appropriate to succeed in keeping risks within management's established risk-tolerance level
Answers
D.
Risk measurements exceed management's tolerance for risk
D.
Risk measurements exceed management's tolerance for risk
Answers
Suggested answer: A

Compliance professionals have a duty to keep senior management and the board apprised of the state of compliance within the bank through which of the following:

A.
Self-monitoring and audit results
A.
Self-monitoring and audit results
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B.
Proactive compliance controls
B.
Proactive compliance controls
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C.
Timely and accurate regulatory reporting
C.
Timely and accurate regulatory reporting
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D.
All of the options mentioned above
D.
All of the options mentioned above
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Suggested answer: D

After a compliance officer develops a base of knowledge of regulations, he or she must begin the art of applying regulations in a risk management environment. Which of the following is NOT out of a few things to be kept in mind when determining what to do FIRST?

A.
Think practically about your role as an advisor. Involve the business units in the decision process rather than making decisions for them
A.
Think practically about your role as an advisor. Involve the business units in the decision process rather than making decisions for them
Answers
B.
Calculate the institution's consolidated risk profile
B.
Calculate the institution's consolidated risk profile
Answers
C.
Make sure you understand the level of risk the bank will tolerate, so decisions do not exceed this limit
C.
Make sure you understand the level of risk the bank will tolerate, so decisions do not exceed this limit
Answers
D.
Add value by analyzing regulatory requirements for the business units before you present proposed or final rules or solutions
D.
Add value by analyzing regulatory requirements for the business units before you present proposed or final rules or solutions
Answers
Suggested answer: B

In the mid-1980s a movement began among the federal supervisory agencies to produce a uniform ARM regulation. In 1988, the Federal Reserve Board added the uniform ARM disclosure requirements to a regulation. Therefore, most of the original OCC ARM consumer protection requirements are now found in this new regulation. Adjustable rate mortgage loans made by national banks may be subject to the OCC's ARM regulation or the requirements of this new regulation, or both. This new regulation is:

A.
Regulation Z
A.
Regulation Z
Answers
B.
Truth in Lending
B.
Truth in Lending
Answers
C.
CFR 34.21, 34.22 and 34.23
C.
CFR 34.21, 34.22 and 34.23
Answers
D.
FIRREA penalty
D.
FIRREA penalty
Answers
Suggested answer: A, B

Which one of the following is out of the FIRREA penalties included in the enforcement section of Adjusted Mortgage Regulation (12 CFR 34)?

A.
Penalties up to $7,500 per day for violations of laws and regulations
A.
Penalties up to $7,500 per day for violations of laws and regulations
Answers
B.
Penalties up to $47,500 per day if violations or unsafe or unsound practices are engaged in recklessly or are part of a pattern of misconduct that causes more than a minimal loss to the bank or any pecuniary gain to the parties involved
B.
Penalties up to $47,500 per day if violations or unsafe or unsound practices are engaged in recklessly or are part of a pattern of misconduct that causes more than a minimal loss to the bank or any pecuniary gain to the parties involved
Answers
C.
Penalties up to $1,375,000 per day against persons who knowingly commit a violation and knowingly or recklessly cause a substantial loss to the bank or a substantial benefit to the party
C.
Penalties up to $1,375,000 per day against persons who knowingly commit a violation and knowingly or recklessly cause a substantial loss to the bank or a substantial benefit to the party
Answers
D.
Penalties up to $6,500 per day for violations of laws and regulations
D.
Penalties up to $6,500 per day for violations of laws and regulations
Answers
Suggested answer: A, C

In Requirements section of Adjusted Mortgage Regulation (12 CFR 34), for loans subject to both the OCC ARM regulation and to Regulation Z, 12 CFR 226.19(b)---that is, loans made to an individual, for personal purposes, secured by the borrower's principal dwelling, and having a term longer than one year--- the index to which the interest rate is tied must be:

A.
Specified in loan documents
A.
Specified in loan documents
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B.
Readily available to and verifiable by the browser
B.
Readily available to and verifiable by the browser
Answers
C.
Multiple values of a chosen measure or a moving average of the chosen measure calculated over a specified period
C.
Multiple values of a chosen measure or a moving average of the chosen measure calculated over a specified period
Answers
D.
A and B only
D.
A and B only
Answers
Suggested answer: D

Subprime borrowers are those with weakened credit histories or reduced repayment capacity. Loans to these borrowers historically have had a higher delinquency rate. Many lenders have expanded their lending programs and added subprime products as a method of meeting their _______________by providing greater credit access to lower-income consumers.

A.
Community Reinvestment Act (CRA) responsibilities
A.
Community Reinvestment Act (CRA) responsibilities
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B.
Fraudulent marketing tactics
B.
Fraudulent marketing tactics
Answers
C.
FTC Act
C.
FTC Act
Answers
D.
Predatory Lending
D.
Predatory Lending
Answers
Suggested answer: A

The banking agencies issued two guidances to caution depository institutions about risks involved in funding non-depository lenders that engage in predatory lending. Predatory and abusive practices include:

A.
High-pressure sales
A.
High-pressure sales
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B.
Excessive fees and interest rate including fees for unnecessary products
B.
Excessive fees and interest rate including fees for unnecessary products
Answers
C.
Balloon payments that may never cause foreclosures
C.
Balloon payments that may never cause foreclosures
Answers
D.
Excessive refinancing with fees included in the new loan
D.
Excessive refinancing with fees included in the new loan
Answers
Suggested answer: A, B

Under Interagency Guidance on Subprime Lending (1999) lending policy must:

A.
Be appropriate to the size and complexity of the operation
A.
Be appropriate to the size and complexity of the operation
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B.
Address the types of products offers and those not authorized
B.
Address the types of products offers and those not authorized
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C.
Require credit file documentation
C.
Require credit file documentation
Answers
D.
All of these
D.
All of these
Answers
Suggested answer: D

The purpose of guidelines for National Banks to Guard against Predatory and Abusive Lending Practices- AL-2003-2 includes all of the following EXCEPT:

A.
Provide examples to national banks of practices that may be abusive
A.
Provide examples to national banks of practices that may be abusive
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B.
Advise banks on how they should avoid abusive practices
B.
Advise banks on how they should avoid abusive practices
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C.
Banks should consider appropriate discount rates, credit loss rates, and prepayment rates when valuing these assets
C.
Banks should consider appropriate discount rates, credit loss rates, and prepayment rates when valuing these assets
Answers
D.
Show how some abusive lending can involve unfair or deceptive practices and therefore violate the Federal Trade Commission Act
D.
Show how some abusive lending can involve unfair or deceptive practices and therefore violate the Federal Trade Commission Act
Answers
Suggested answer: C
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