Banking CRCM Exam
CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) (Page 12 )

Updated On: 12-Jan-2026

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?

  1. Yes. First National Bank did not know of it, so it may reimburse a negotiating bank.
  2. No. First National Bank is under a duty to determine the underlying conditions of any letter of credit it pays.
  3. No. First National Bank should request a copy of the letter of credit at the time of its payment and then refuse to pay once it is aware of the provision.
  4. Yes, provided ABC Company is not a participant in the boycott.

Answer(s): A



Country A (a foreign country that is boycotting Country B, another foreign country) has ordered goods from ABC, a U.S. corporation. Country A has opened a letter of credit with Overseas, Inc., a foreign bank. The letter of credit specifies that ABC must certify that it does not do business with Country B. Overseas, Inc., sends a telegram to First National Bank, a U.S. bank, stating the major terms and conditions of the letter of credit and asking First National Bank to confirm the letter of credit. The telegram does not state the boycott provisions. Overseas mails the letter of credit to First National Bank and asks First National Bank to confirm it. What may First National Bank do?

  1. First National Bank must confirm it if it previously agreed to do so.
  2. First National Bank may advise ABC of the letter of credit and administer its disposal, but may not confirm it and must report it to the Department of Commerce and the IRS.
  3. First National Bank may do nothing but return the letter of credit to the issuing bank and report to the IRS.
  4. First National Bank must confirm the letter of credit but should also report it to the Department of Commerce.

Answer(s): B



Which of the following is NOT a requirement when a bank pays an employee a fee for referring a high-net-worth or institutional customer to a broker?

  1. The bank must have a written agreement with the broker
  2. The bank must give a disclosure to the customer
  3. The bank must reasonably believe that the customer is a high net worth or institutional customer
  4. The employee must be registered with the bank's regulatory agency

Answer(s): D



Which of the following is a high-net-worth customer?

  1. An individual with $5 million in assets, including her home
  2. A corporation with $15 million in revenues
  3. A couple with a net worth of $10 million
  4. An individual who is not acting with his spouse, with $1 million in assets and another $3 million in community property

Answer(s): C



Which of the following advertising activities indicate that a bank would NOT be exempt from SEC registration requirements?

  1. Listing its securities transfer services as a service the bank provides for IRA accounts along with other IRA benefits
  2. Listing its securities services for trust accounts in the bank's extensive trust services brochure
  3. Mentioning in a print advertisement that the bank provides accommodation securities trades for its regular custodial accounts
  4. Stating in an advertisement concerning employee benefit plan services that the bank provides securities brokerage services for employee benefit plan accounts

Answer(s): C



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