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CERTIFIED REGULATORY COMPLIANCE MANAGER (CRCM) Questions 148–149 (page: 90)

Updated On: 9-Feb-2026

ACME Bank is a state nonmember bank with all of its offices in one state.However, it also has an Internet Web site where it advertises consumer credit and accepts applications from a five-state regional areA. Two of the states are community property states. The other three are not. What is the best explanation for what ACME bank's management should do to comply with the FDIC ECOA spousal signature guidance?

  1. Because ACME has all of its offices within one state, it only has to be knowledgeable of the legal requirements of that state regarding spousal property rights and can apply those laws to all of its operations.
  2. ACME must become familiar with the laws of each of the five states and ask for spouse signatures only when appropriate under the law.
  3. ACME can choose any of the state laws where it operates to apply to its consumer lending operations.
  4. ACME should make only business-purpose loans to avoid the spousal signature rules.

Answer(s): B



ACME Bank is a state nonmember bank with all of its offices in one state.However, it also has an Internet Web site where it advertises consumer credit and accepts applications from a five-state regional areA. Two of the states are community property states. The other three are not. What is the best explanation for what ACME bank's management should do to comply with the FDIC ECOA spousal signature guidance?

  1. Because ACME has all of its offices within one state, it only has to be knowledgeable of the legal requirements of that state regarding spousal property rights and can apply those laws to all of its operations.
  2. ACME must become familiar with the laws of each of the five states and ask for spouse signatures only when appropriate under the law.
  3. ACME can choose any of the state laws where it operates to apply to its consumer lending operations.
  4. ACME should make only business-purpose loans to avoid the spousal signature rules.

Answer(s): B



ACME Bank is a state nonmember bank with all of its offices in one state.However, it also has an Internet Web site where it advertises consumer credit and accepts applications from a five-state regional areA. Two of the states are community property states. The other three are not. What is the best explanation for what ACME bank's management should do to comply with the FDIC ECOA spousal signature guidance?

  1. Because ACME has all of its offices within one state, it only has to be knowledgeable of the legal requirements of that state regarding spousal property rights and can apply those laws to all of its operations.
  2. ACME must become familiar with the laws of each of the five states and ask for spouse signatures only when appropriate under the law.
  3. ACME can choose any of the state laws where it operates to apply to its consumer lending operations.
  4. ACME should make only business-purpose loans to avoid the spousal signature rules.

Answer(s): B



Hector Martinez is a loan officer in a non-community property state. He receives a verbal request for a small business working capital loan from Leon Rogers for his technology consulting business. The business is a sole proprietorship. Mr. Rogers gives Hector a written business plan for his business, a financial statement for the business for the past two years, and a personal financial statement that includes information on himself and his wife. Can Hector assume that the application is a joint application from Mr. Rogers and his wife?

  1. Yes. Because the financial statement is signed by both Mr. and Mrs. Rogers and includes joint information, the application can be considered to be from both spouses.
  2. Yes. Because the business is a sole proprietorship, the spouse's financial information is important.
  3. No. The bank cannot assume the application is a joint one simply on the basis of submission of joint financial information.
  4. No. Because the business is a sole proprietorship, the bank should assume the application is for individual credit.

Answer(s): C



Hector Martinez is a loan officer in a non-community property state. He receives a verbal request for a small business working capital loan from Leon Rogers for his technology consulting business. The business is a sole proprietorship. Mr. Rogers gives Hector a written business plan for his business, a financial statement for the business for the past two years, and a personal financial statement that includes information on himself and his wife. Can Hector assume that the application is a joint application from Mr. Rogers and his wife?

  1. Yes. Because the financial statement is signed by both Mr. and Mrs. Rogers and includes joint information, the application can be considered to be from both spouses.
  2. Yes. Because the business is a sole proprietorship, the spouse's financial information is important.
  3. No. The bank cannot assume the application is a joint one simply on the basis of submission of joint financial information.
  4. No. Because the business is a sole proprietorship, the bank should assume the application is for individual credit.

Answer(s): C



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