Banking CRCM Exam
CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) (Page 22 )

Updated On: 12-Jan-2026

Federal regulations define special-purpose credit-12 CFR 202.8 to include:

  1. Any credit assistance program authorized by federal or state law for the benefit of an economically disadvantaged class of persons
  2. Any credit assistance program offered by a not-for-profit organization for the benefit of its members or for the benefit of an economically disadvantaged class of person
  3. A special-purpose credit program must not discriminate on a prohibited basis; however, it can require its participants to share a particular characteristic (such as race or sex) provided the requirement was not established to evade the requirements of the ECOA. If the participants must share a common characteristic, the bank may collect information on that characteristic to determine eligibility
  4. If the program includes financial need as a criterion, the creditor can never request and consider information regarding the applicant

Answer(s): A,B,C



Credit scoring systems:

  1. Evaluate an applicant's creditworthiness mechanically, based on key attributes of the applicant and aspects of the transaction, and determine, alone or in conjunction with an evaluation of additional information about the applicant, whether an applicant is deemed creditworthy
  2. Are evaluated by regulatory agencies to determine whether they are empirically derived and statistically sound and to examine:
    The bank's policies on the use of the credit scoring system Training of bank employees on the use of the system The number of high-side and low-side overrides of the system
  3. Both of these
  4. None of these

Answer(s): C



In Processing and evaluating applications--12 CFR 202.6, protected income part is also under discussion. Which of the following considerations is NOT its part?

  1. Public assistance income may not consider whether an applicant's income is from a public assistance source
  2. Public assistance income may consider as it relates to another pertinent element of creditworthiness
  3. May consider length of time public assistance income will be received, whether the applicant will continue to qualify for the income, and whether the income can be garnished
  4. Can discount or refuse to consider the following:
    Part-time income
    Annuities
    Pensions
    Retirement benefits
    Alimony, child support, and separate maintenance payments to the extent they are likely to be consistently made

Answer(s): D



A compliance professional is a member of the task force studying how the bank can reduce customer complaints about holding deposits. One proposed solution involves purchasing an expensive system that will reduce the number of holds placed by evaluating the customer's history and relationship with the bank. Which of the following roles is MOST important for the compliance professional on the task force?

  1. Developing training for tellers who will use the new system
  2. Setting parameters for what the system should review to determine the strength of the customer relationship
  3. Validating the system to ensure it complies with regulatory restrictions
  4. Conducting a cost-benefit analysis to determine if the system is the best solution

Answer(s): C



Of the following loans made by a national bank, which loan is NOT covered by the OCC ARM regulation?

  1. A loan to purchase a single-family dwelling to be used as a residence, secured by the dwelling with an adjustable interest rate
  2. A loan made to purchase a mobile home to be used as rental property, secured by the home with a variable interest rate
  3. A loan made to purchase an eight-unit apartment complex, secured by the building, made payable on demand with a variable rate of interest
  4. A loan made to purchase a duplex, secured by the dwelling, amortized over 15 years with a 5-year maturity, at a variable rate of interest

Answer(s): C



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