CAM Regulatory Compliance 2 — Questions and Answers
Question 1: Under the Bank Secrecy Act (BSA), what is the dollar threshold that triggers a Currency Transaction Report (CTR)?
- $5,000
- $10,000 (Correct answer)
- $25,000
- $50,000
Correct answer: $10,000
Financial institutions must file a CTR for cash transactions exceeding $10,000 in a single business day.
Question 2: A client structures multiple cash deposits of $9,500 each over several days to avoid CTR reporting. This practice is known as:
- Layering
- Integration
- Structuring (Correct answer)
- Placement
Correct answer: Structuring
Structuring (also called 'smurfing') is the illegal practice of breaking large transactions into smaller amounts to evade reporting requirements.
Question 3: Which federal agency is primarily responsible for enforcing the Bank Secrecy Act?
- SEC
- FDIC
- FinCEN (Correct answer)
- OCC
Correct answer: FinCEN
The Financial Crimes Enforcement Network (FinCEN) administers and enforces the BSA on behalf of the Treasury Department.
Question 4: Under Regulation Z (Truth in Lending), what must be prominently disclosed before a consumer credit account is opened?
- The lender's internal credit scoring model
- The Annual Percentage Rate and key loan terms (Correct answer)
- The borrower's FICO score
- The institution's reserve requirements
Correct answer: The Annual Percentage Rate and key loan terms
Regulation Z requires lenders to clearly disclose the APR and material terms so consumers can compare credit offers.
Question 5: A Suspicious Activity Report (SAR) must generally be filed within how many calendar days of detecting a suspicious transaction?
- 15 days
- 30 days (Correct answer)
- 45 days
- 60 days
Correct answer: 30 days
Financial institutions are required to file a SAR within 30 days (extendable to 60 days with written notice) of detecting a suspicious transaction.
Question 6: Which regulation implements the Community Reinvestment Act, requiring banks to meet the credit needs of all segments of their communities?
- Regulation B
- Regulation BB (Correct answer)
- Regulation E
- Regulation CC
Correct answer: Regulation BB
Regulation BB implements the CRA, outlining how banks must document and demonstrate their lending in low- and moderate-income communities.
Question 7: The 'red flag rules' under FACTA require financial institutions to implement programs to detect and respond to indicators of:
- Money laundering
- Identity theft (Correct answer)
- Insider trading
- Tax evasion
Correct answer: Identity theft
FACTA's Red Flag Rules require covered entities to create written programs for identifying and responding to identity theft warning signs.
Under the Bank Secrecy Act (BSA), what is the dollar threshold that triggers a Currency Transaction Report (CTR)?