CRCM Trivia 3 — Questions and Answers
Question 1: Under the Equal Credit Opportunity Act (ECOA), how many days does a creditor have to notify an applicant of adverse action on a credit application?
- 15 days
- 30 days (Correct answer)
- 45 days
- 60 days
Correct answer: 30 days
ECOA and Regulation B require creditors to notify applicants of adverse action within 30 days of receiving a completed application.
Question 2: The Home Mortgage Disclosure Act (HMDA) requires financial institutions to collect and report data primarily to identify what?
- Fraudulent mortgage applications
- Possible fair lending violations and underserved communities (Correct answer)
- Borrowers who default on their loans
- Interest rate manipulation by mortgage lenders
Correct answer: Possible fair lending violations and underserved communities
HMDA data is used by regulators and the public to identify potential discriminatory lending patterns and determine whether financial institutions are serving community needs.
Question 3: Which of the following is NOT a protected class under the Fair Housing Act?
- Religion
- National origin
- Source of income (Correct answer)
- Familial status
Correct answer: Source of income
The federal Fair Housing Act protects race, color, religion, sex, national origin, disability, and familial status, but does not protect source of income at the federal level.
Question 4: What is the maximum civil money penalty per day for knowing violations of the Bank Secrecy Act?
- $10,000
- $25,000
- $1,000,000 (Correct answer)
- $10,000,000
Correct answer: $1,000,000
Knowing violations of the BSA can result in civil money penalties up to $1,000,000 per day or twice the amount of the transaction, whichever is greater.
Question 5: Under the Electronic Fund Transfer Act (EFTA), what is a consumer's maximum liability for unauthorized electronic transfers if they notify the bank within 2 days?
- $0
- $50 (Correct answer)
- $500
- $5,000
Correct answer: $50
Under Regulation E, if a consumer reports an unauthorized EFT within two business days, their liability is limited to $50.
Question 6: The Office of Foreign Assets Control (OFAC) administers and enforces economic sanctions programs. OFAC is part of which federal department?
- Department of Justice
- Department of State
- Department of the Treasury (Correct answer)
- Department of Homeland Security
Correct answer: Department of the Treasury
OFAC is an office of the U.S. Department of the Treasury that administers and enforces economic and trade sanctions.
Question 7: Which examination procedure involves testing a random sample of loan files to identify patterns of potential discrimination?
- Compliance management system review
- Comparative file review (Correct answer)
- Self-assessment audit
- Mystery shopping
Correct answer: Comparative file review
Comparative file review involves examiners comparing loan files from different demographic groups to identify disparities in treatment that may indicate discrimination.
CRCM Trivia 3
Under the Equal Credit Opportunity Act (ECOA), how many days does a creditor have to notify an applicant of adverse action on a credit application?