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Free American Bankers Association Certified Regulatory Compliance Manager CRCM Exam Questions

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Question 1

First National Bank opened a letter of credit in favor of ABC Co., a U.S. company, for ABC's sale of goods to Country X, a foreign country that participates in a boycott. The letter of credit contains no boycott provisions, but First National Bank knows that ABC Co. has agreed to supply a certification to Country X that ABC has not dealt with any blacklisted firms as a condition of receiving the letter of credit in its favor. What should First National Bank do?

Correct Answer: C. Not implement the letter of credit

Question 2

Which of the following primary purpose/s were behind the Electronic Fund Transfer Act (EFTA)?

Correct Answer: C. Both A and B

Question 3

____________ is an agent or a subagent of the owner of an item; agency terminates when it receives payment for an item in finally collected funds and makes the proceeds available to the sender, and the time for commencing all actions against it has expired.

Correct Answer: B. The Reserve Bank

Question 4

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?

Correct Answer: C. Prepare a summary document that outlines the effects the proposed rule would have on the bank's operations

Question 5

Your institution has identified a transaction by an existing depositor that should be blocked under OFAC requirements. The branch manager contacts you for specific instructions. Before reporting the transaction to OFAC, what should the bank do?

Correct Answer: A. Reject the transaction

Question 6

Of the following actions, which one is NOT recommended by the OCC's advisory letter as a necessary tool of management oversight of insurance and annuity sales?

Correct Answer: B. Establishing a separate insurance agency

Question 7

In April Lillian Redmond, the teller supervisor for First National Bank, discovers five counterfeit $20 bills in several teller drawers. In May and in June she discovers two additional counterfeit $20 bills. She has no knowledge of criminal activity on the part of any of the bank's employees or customers. She does not suspect any particular person in this transaction. Which of the following statements is true?

Correct Answer: C. Ms. Redmond need not file a SAR on this incident because the total amount is less than $25,000.

Question 8

Issuing Bank, a foreign bank, maintains an account with First National Bank, a U.S. bank. Issuing Bank issues a letter of credit in favor of ABC, Inc., a U.S. corporation. The letter of credit contains a boycott provision. The letter of credit provides that any negotiating bank may obtain reimbursement from Issuing Bank's account at First National Bank by certifying that the conditions of the letter of credit have been met. Issuing Bank does not send First National Bank a copy of the letter of credit. May First National Bank reimburse negotiating banks for the letter of credit when it contains a boycott provision?

Correct Answer: A. Yes. First National Bank did not know of it, so it may reimburse a negotiating bank.

Question 9

Definition of completed application---12 CFR 202.2(f) is:

Correct Answer: A. An application for which the bank has received all the information it regularly considers in evaluation, including credit reports, verifications, and so forth; B. The creditor must be reasonably diligent in collecting information to complete the application (for example, ordering credit bureau reports)

Question 10

Bob's wife is HIV-positive due to a blood transfusion during an appendectomy 15 years ago. She is not yet sick, but takes medication to prevent the onset of AIDS. Bob occasionally needs to take time off from work to take her for testing at Johns Hopkins in Baltimore. Because of complaints about Bob's exposure to this disease, employees have asked HR to limit his contact with them and with customers. The bank has asked Bob not to eat in the lunchroom with the other employees and has placed Bob in a position where he has limited customer contact. Does this company have any potential ADA liability?

Correct Answer: D. Yes. Because the manager has regarded Bob as having a disability, he has been ''regarded as'' disabled and the ADA applies

Question 11

In which of the following circumstances is it LEAST appropriate for a bank to file a SAR regarding Internet activity?

Correct Answer: D. Bank determines through its transaction-monitoring program that a customer is making electronic transfers between his own checking and savings accounts that are just below the $10,000 reporting level

Question 12

A Reserve Bank makes the following warranties when it handles___________:

* For all items, the Reserve Bank warrants that the returned checks bear all endorsements by all parties that previously handled the checks

* For all electronic items, the Reserve Bank warrants all of the

* Regulation CC warranties as though they were paper checks

* For electronic items that are not representations of substitute checks, the Reserve Bank warrants the following to the bank to which it sends the item:

(a) The electronic portion of the item accurately represents all of the information on the front and back of the check as of the time the check was truncated

(b) All MICR line information is contained on the item

(c) The item conforms to the technical standards set forth in the operating circular

(d) No person will receive a transfer, presentment, or return, or otherwise be charged for the item such that the person will be asked to make payment based on an item he or she has already paid

Correct Answer: A. A returned item

Question 13

In Sender's agreement-12 CFR 210.28 it is clearly mentioned that:

Correct Answer: B. Senders have the right to create overdrafts in their accounts at the Reserve Bank; any overdraft is due and payable, without demand, at the end of the funds transfer day, when the Reserve Bank deems itself to be insecure, or at the time the sender suspends payments or is closed, whichever is earlier; C. Sender gives the Reserve Bank a security interest in all of sender's assets that are in the possession of the Reserve Bank to secure any obligations to the Reserve Bank, including an overdraft

Question 14

Roger Jameson is the head of the consumer loan department at First National Bank. He is a regular participant in a lending committee of a local finance trade association. The committee meets once a month at a local hotel. After the committee meetings, Roger and several other committee members who are officers at other banks in town go to a hotel restaurant and talk for a couple of hours before leaving. During these informal conversations Roger learned that the other members require the car dealerships in town that sell consumer installment contracts to the banks to refrain from selling them to local savings and loan associations. Roger believes that this is a good idea and would like to implement it at First National. Is there a problem with doing so?

Correct Answer: D. Yes. Restricting the dealerships is a restraint of trade.

Question 15

It is an extension of credit will be deemed to be made to an insider if the proceeds are transferred to the insider or used for the insider's benefit. This rule does not apply if the credit is made on substantially the same terms and conditions as those made to a noninsider and if the proceeds are used in a bona fide transaction involving the acquisition of property, goods, or services from the insider. What is it?

Correct Answer: A. Tangible economic benefit rule012 CFR 215.3(f)