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CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) Questions 98–99 (page: 60)

Updated On: 9-Feb-2026

ABC National Bank regularly purchases mortgage loans from ACME Mortgage Company, a local mortgage broker. ACME places a mandatory arbitration clause in each of its mortgage documents. ACME believes this clause is necessary because of state laws governing arbitration. Is this clause a problem for ABC National?

  1. No, unless other predatory or abusive lending practices are evident in the loans sold by ACME.
  2. Yes, the clause is a sign of an abusive lender, and the bank should not purchase the loans.
  3. Yes, the bank should make ACME strike the clause from future loans.
  4. No, this is a common practice and the bank can ignore it.

Answer(s): A



ABC National Bank regularly purchases mortgage loans from ACME Mortgage Company, a local mortgage broker. ACME places a mandatory arbitration clause in each of its mortgage documents. ACME believes this clause is necessary because of state laws governing arbitration. Is this clause a problem for ABC National?

  1. No, unless other predatory or abusive lending practices are evident in the loans sold by ACME.
  2. Yes, the clause is a sign of an abusive lender, and the bank should not purchase the loans.
  3. Yes, the bank should make ACME strike the clause from future loans.
  4. No, this is a common practice and the bank can ignore it.

Answer(s): A



ABC National Bank regularly purchases mortgage loans from ACME Mortgage Company, a local mortgage broker. ACME places a mandatory arbitration clause in each of its mortgage documents. ACME believes this clause is necessary because of state laws governing arbitration. Is this clause a problem for ABC National?

  1. No, unless other predatory or abusive lending practices are evident in the loans sold by ACME.
  2. Yes, the clause is a sign of an abusive lender, and the bank should not purchase the loans.
  3. Yes, the bank should make ACME strike the clause from future loans.
  4. No, this is a common practice and the bank can ignore it.

Answer(s): A



The OCC recommends all but one of the following actions to help prevent a national bank's purchasing or acquiring predatory or abusive loans. Which practice is NOT recommended?

  1. Establish policies on the bank's relationship with third-party brokers and originators
  2. Review loan documentation
  3. Audit the third-party broker
  4. Require the broker to establish a reserve account for legal contingencies

Answer(s): D



The OCC recommends all but one of the following actions to help prevent a national bank's purchasing or acquiring predatory or abusive loans. Which practice is NOT recommended?

  1. Establish policies on the bank's relationship with third-party brokers and originators
  2. Review loan documentation
  3. Audit the third-party broker
  4. Require the broker to establish a reserve account for legal contingencies

Answer(s): D



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