Banking CRCM Exam
CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) (Page 20 )

Updated On: 12-Jan-2026

A bank has a large mortgage department as well as a high HMDA error rate. An expensive software program could automate the process, but the business unit manager does not want to purchase the software because of its expense. Though it is not as efficient, the manager prefers to make some improvements to the manual process, add some more robust monitoring procedures, and opt not to purchase the software. What should the compliance professional do?

  1. Elevate the issue to a higher authority to force the mortgage department unit to purchase the software
  2. Nothing; the compliance professional's job is done with the completed research
  3. Document the fact that the level of risk present with manual systems is acceptable to the mortgage department business unit
  4. Write a memo to the president of the bank that explains the risk assessment for this area

Answer(s): C



A bank's president would like to begin offering a new home equity line of credit product within two weeks. In all cases the borrower's principal dwelling will secure the loan. The president has already launched a planned advertising campaign for the bank's major service markets. What should the compliance professional do FIRST?

  1. Hire an attorney to write the appropriate legal documents and disclosures
  2. Write a memo to the president explaining why the compliance professional should have been in on the process at an earlier date
  3. Begin training sessions for the lending and loan operations staff on the compliance issues involved
  4. Perform a risk assessment to determine the bank's level of risk in offering this new product

Answer(s): D



Legislation was recently enacted to reform consumer real estate protection laws, and the bank will now have to change the way it documents, discloses, and advertises real estate loans, an integral product line at your bank. What should the compliance professional do FIRST to implement the new law within the bank?

  1. Read the law and write a new real estate compliance policy
  2. Form a task force of the business unit managers whose departments will be affected by the law to collectively form an action plan
  3. Talk to the bank president about the need for more resources in compliance
  4. Sign up all bank personnel affected by the changes for a seminar on the new law

Answer(s): B



A consumer reporting agency may furnish a consumer report

  1. If not authorized in writing by the consumer
  2. In response to a court order having jurisdiction or a subpoena issued by a federal grand jury or review or collection of an account of the consumer
  3. In connection with a credit or insurance transaction
  4. For employment purposes
    Before procuring a consumer report, an employer
    Must disclose to the individual in writing that a consumer report may be obtained Must obtain written authorization from the individual before procuring the report

Answer(s): B,C,D



According to FDIC Guidance on Spousal Signature Provisions, if the creditor requires the spouse's signature on an instrument that imposes personal liability, the creditor's belief should be:

  1. Supported by a thorough review of pertinent statutes, decisional law, or an opinion of the state's attorney general
  2. Supported by a thorough review of pertinent statutes
  3. Supported by decisional law
  4. Supported by an opinion of the state's attorney general

Answer(s): A



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