CRCM Certified Regulatory Compliance Manager MCQ 3 — Questions and Answers
Question 1: Under the Real Estate Settlement Procedures Act (RESPA), which section prohibits kickbacks and unearned fees in connection with federally related mortgage loans?
- Section 6
- Section 8 (Correct answer)
- Section 10
- Section 12
Correct answer: Section 8
RESPA Section 8 prohibits giving or accepting fees, kickbacks, or anything of value in exchange for referrals of settlement service business.
Question 2: The Military Lending Act (MLA) caps the Military Annual Percentage Rate (MAPR) for covered loans to active-duty servicemembers at:
- 18%
- 21%
- 28%
- 36% (Correct answer)
Correct answer: 36%
The MLA imposes a 36% MAPR cap on consumer credit extended to covered active-duty servicemembers and their dependents.
Question 3: Which of the following is NOT a required element of an effective compliance management system (CMS) as described by the CFPB?
- Board and management oversight
- Compliance program
- Customer complaint response
- Annual third-party vendor audits (Correct answer)
Correct answer: Annual third-party vendor audits
The CFPB's four CMS elements are board/management oversight, compliance program, consumer complaint response, and compliance audit — not specifically annual third-party vendor audits.
Question 4: Under the Home Mortgage Disclosure Act (HMDA), which type of institution is generally required to report HMDA data?
- Any entity that originates at least one mortgage loan per year
- Depository institutions meeting asset and loan volume thresholds in metropolitan statistical areas (Correct answer)
- All non-bank mortgage companies regardless of size
- Only institutions supervised by the Federal Reserve
Correct answer: Depository institutions meeting asset and loan volume thresholds in metropolitan statistical areas
HMDA coverage depends on asset size, loan volume thresholds, and geographic location in or near an MSA for depository institutions.
Question 5: A compliance officer at a credit union is reviewing a member's loan file and finds no documentation of income verification. This most likely violates which regulatory requirement?
- Regulation B's adverse action requirements
- Ability-to-Repay (ATR) rule under Regulation Z (Correct answer)
- Regulation C HMDA data collection
- RESPA's Good Faith Estimate requirements
Correct answer: Ability-to-Repay (ATR) rule under Regulation Z
The ATR rule requires lenders to make a reasonable, good-faith determination of the consumer's ability to repay based on verified income and other financial information.
Question 6: Under the Servicemembers Civil Relief Act (SCRA), what is the interest rate cap applied to pre-service debts of active-duty servicemembers?
- 3%
- 4%
- 6% (Correct answer)
- 8%
Correct answer: 6%
The SCRA caps interest rates on debts incurred before active military service at 6% per year for the duration of the active-duty period.
Question 7: The purpose of a risk-based compliance monitoring program is primarily to:
- Ensure all regulations receive equal review time
- Concentrate monitoring resources where the risk of harm is greatest (Correct answer)
- Replace annual compliance audits
- Document all regulatory changes for management
Correct answer: Concentrate monitoring resources where the risk of harm is greatest
Risk-based monitoring allocates compliance resources to areas with the highest potential for regulatory violations and consumer harm.
CRCM Certified Regulatory Compliance Manager MCQ 3
Under the Real Estate Settlement Procedures Act (RESPA), which section prohibits kickbacks and unearned fees in connection with federally related mortgage loans?