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Which of the following usually comes under the heading of abusive lending?

A.
Abusive lending usually is defined by a variety of lending practices
A.
Abusive lending usually is defined by a variety of lending practices
Answers
B.
It is the excessive and hidden fees in the amount financed
B.
It is the excessive and hidden fees in the amount financed
Answers
C.
A fundamental characteristic is aggressive marketing of credit to prospective borrowers who cannot repay it on the terms offered
C.
A fundamental characteristic is aggressive marketing of credit to prospective borrowers who cannot repay it on the terms offered
Answers
D.
Typically, such loans are underwritten on the liquidation value of the collateral rather than the creditworthiness of the borrower
D.
Typically, such loans are underwritten on the liquidation value of the collateral rather than the creditworthiness of the borrower
Answers
Suggested answer: A, C, D

______________ is frequent refinancing that do not benefit the borrower. This practice can result in borrower injury from the fees imposed and from the fact that it decreases home equity and increases the consumer's debt burden, thus increasing the chance of foreclosure.

A.
Loan flipping
A.
Loan flipping
Answers
B.
Loan refinancing
B.
Loan refinancing
Answers
C.
Securitization
C.
Securitization
Answers
D.
Subprime loans
D.
Subprime loans
Answers
Suggested answer: A

Guidelines for National Banks to Guard against Predatory and Abusive Lending Practices---AL-2003-2 says that refusing to purchase the following types of loans can reduce the possibility of purchasing abusive mortgage loans EXCEPT:

A.
Loans in which the lender has not adequately determined the borrower's ability to repay the debt
A.
Loans in which the lender has not adequately determined the borrower's ability to repay the debt
Answers
B.
Loans subject to the Home Ownership and Equity Protection Act (HOEPA)
B.
Loans subject to the Home Ownership and Equity Protection Act (HOEPA)
Answers
C.
Loans with points and fees in excess of 5 percent of the loan amount, except in cases where the higher amount was to prevent the loan from being unprofitable
C.
Loans with points and fees in excess of 5 percent of the loan amount, except in cases where the higher amount was to prevent the loan from being unprofitable
Answers
D.
Loans in which a prepaid multiple-premium credit insurance policy was included in the amount financed
D.
Loans in which a prepaid multiple-premium credit insurance policy was included in the amount financed
Answers
Suggested answer: D

Predatory lending practices can adversely affect:

A.
A bank's CRA rating
A.
A bank's CRA rating
Answers
B.
Equity shipping
B.
Equity shipping
Answers
C.
Loan quality control reviews
C.
Loan quality control reviews
Answers
D.
Truth in Lending Act
D.
Truth in Lending Act
Answers
Suggested answer: A

The purpose of advisory letter in Avoiding Predatory and Abusive Lending Practices in Brokered and Purchased Loans- AL-2003-3 is to:

A.
Adopt sound credit underwriting policies
A.
Adopt sound credit underwriting policies
Answers
B.
Alert national banks to the risks they take if they make loans through brokers or purchase loans that contain or reflect abusive or predatory terms or practices
B.
Alert national banks to the risks they take if they make loans through brokers or purchase loans that contain or reflect abusive or predatory terms or practices
Answers
C.
Adopt policies that address the circumstances under which the bank would make loans that have features associated with abusive lending practices
C.
Adopt policies that address the circumstances under which the bank would make loans that have features associated with abusive lending practices
Answers
D.
Make loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
D.
Make loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
Answers
Suggested answer: B

Examples of unfair practices mentioned in guidelines against Predatory and Abusive Lending includes loan flipping and loan equity stripping. It is said that:

A.
Loan flipping may be unfair because it increases the chances of foreclosure by decreasing home equity and increasing debt burden
A.
Loan flipping may be unfair because it increases the chances of foreclosure by decreasing home equity and increasing debt burden
Answers
B.
Equity stripping is the practice of making loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
B.
Equity stripping is the practice of making loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
Answers
C.
Loan flipping is the practice of making loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
C.
Loan flipping is the practice of making loans secured by the consumer's home but with high, up-front fees that are financed and secured by the home
Answers
D.
Equity stripping may be unfair because it increases the chances of foreclosure by decreasing home equity and increasing debt burden
D.
Equity stripping may be unfair because it increases the chances of foreclosure by decreasing home equity and increasing debt burden
Answers
Suggested answer: A, B

Which of the following are recommended practices In Avoiding Predatory and Abusive Lending Practices in Brokered and Purchased Loans---AL-2003-3?

A.
Have written agreements with third-party brokers that specifically and clearly address the rights and responsibilities of each party. Written agreements should 1. Ensure that no inappropriate compensation exists 2. Provide for indemnification to the bank 3. Enable banks to exit the arrangement through a termination procedure 4. Provide for the bank's and the OCC's ability to access all records of the third party and to audit the third party's operations
A.
Have written agreements with third-party brokers that specifically and clearly address the rights and responsibilities of each party. Written agreements should 1. Ensure that no inappropriate compensation exists 2. Provide for indemnification to the bank 3. Enable banks to exit the arrangement through a termination procedure 4. Provide for the bank's and the OCC's ability to access all records of the third party and to audit the third party's operations
Answers
B.
Verify that brokers and originators have established policies to ensure that loans will comply with all applicable laws
B.
Verify that brokers and originators have established policies to ensure that loans will comply with all applicable laws
Answers
C.
Establish an effective management information system to monitor the performance of third-party brokers and originators
C.
Establish an effective management information system to monitor the performance of third-party brokers and originators
Answers
D.
All of the above
D.
All of the above
Answers
Suggested answer: D

Below mentioned list shows the significant risks of _______________.

Borrowers with cash-flow difficulties

Borrowers with no lower-cost credit alternatives

Minimal analysis of borrower's ability to repay the loan

Minimal review of borrower's credit history

Credit is usually unsecured

A.
Payday lending
A.
Payday lending
Answers
B.
Loan flipping
B.
Loan flipping
Answers
C.
Equity stripping
C.
Equity stripping
Answers
D.
None of these
D.
None of these
Answers
Suggested answer: A

Banks must maintain an ____________adequate to absorb estimated credit losses from payday loans. Banks should evaluate the collectability of accrued fees and finance charges on payday loans and ensure that this income is appropriately measured.

A.
TILA
A.
TILA
Answers
B.
FCRA
B.
FCRA
Answers
C.
ALLL
C.
ALLL
Answers
D.
A and B both
D.
A and B both
Answers
Suggested answer: C

Safety and soundness concerns in FDIC Payday Lending Guidance clearly mention that there should be adequate capital as Minimum capital requirements are not enough to offset the risks of payday loans. Banks should hold capital against its subprime portfolio in amounts:

A.
That are 1 to 5 times greater than normal
A.
That are 1 to 5 times greater than normal
Answers
B.
That are 1 to 3 times greater than normal
B.
That are 1 to 3 times greater than normal
Answers
C.
That are 1 to 3 times lower than normal
C.
That are 1 to 3 times lower than normal
Answers
D.
That should be between 2-5 in comparison to normal
D.
That should be between 2-5 in comparison to normal
Answers
Suggested answer: B
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