The CE Quizzes in ABA Bank Compliance provide up to six continuing education credits per year to those who
hold the CRCM certification. Each quiz consists of ten questions taken directly from the articles in each issue.
The quizzes have been pre-approved by the ICB for 1.0 credits each. You must correctly answer seven out of ten
questions to receive the credit. To take the quiz, please go to ICB Certification Manager, aba.csod.com/client/aba/
default.aspx. After you login, click on your certification on the home page which will take you to the “Certification
Details” page. Locate the quiz, select “Request” to launch the quiz. Quiz credits are automatically uploaded to
your record. If you have any questions, please contact ICB at firstname.lastname@example.org.
The Mortgage Servicing Rule—Are You Prepared?
by Liza Warner, CPA, CFSA, CRMA, and Jim Shankle, CFSA
1. The Bureau issued a final rule in August 2016 titled Amendments
to the 2013 Mortgage Rules Under the Real Estate Settlement
Procedures Act (Regulation X) and the Truth in Lending Act
(Regulation Z). This final rule is commonly referred to as:
a. The 2016 Mortgage Servicing Rule (the Rule).
b. The 2013 Mortgage Servicing Rule (MSR).
c. The XYMSR.
d. The TILA Rule.
2. The Bureau revised several loss mitigation requirements
included within Regulation X, that require the servicer to do all
of the following EXCEPT:
a. Execute loss mitigation requirements more than once during the
life of the loan for borrowers that become current, but subsequently
submit a loss mitigation application.
b. Join the foreclosure action of either a superior or subordinate
c. Provide a prescribed written notice to the borrower within 365 days
(excluding Saturdays, Sundays and legal holidays) after it receives
a completed loss mitigation application.
d. Select a reasonable date for the borrower to provide documents
and information to complete a loss mitigation application.
3. The Bureau issued an interpretive rule under the FDCPA. It
provides safe harbor from liability for servicers acting in
compliance with mortgage servicing rules in the following
a. When communicating information about a mortgage loan with
confirmed successors in interest.
b. When providing the written early intervention notice required
c. When responding to borrowers who initiate communication
related to loss mitigation after the borrower has invoked the
cease communication right within the FDCPA.
d. When responding to customers who have defaulted on loans
in flood areas.
Implementing HMDA 2018: Nearing Critical Mass
By Rick Kohrumel, CRCM, CAMS
4. The new “lines of business” within the new HMDA data
responsibilities includes all the following EXCEPT:
a. Residential mortgage.
5. Which is NOT considered a HMDA data point?
a. Universal Loan Identifier (ULI).
b. Application date .
c. Collection of borrower blood type, height, weight.
d. Construction method.
Update on Commercial Loan Data Reporting:
What to Consider Today in Anticipation of the
by Carl Pry, CRCM, CRP
6. The Bureau has already publicized its interest in commercial
lending, especially small business lending, and “small” refers to:
a. The size of the loan.
b. The size of the business.
c. The size of the bank making the loan.
d. Whether the loan is made to a minority.
7. For a covered small business or minority- or women-owned
business loan application, the statute requires all of the
following information be compiled by the bank EXCEPT:
a. Application number and date received.
b. Type and purpose of the credit being applied for.
c. Amount of credit or credit limit applied for and the amount approved.
d. Gross annual revenue of the business during its previous 10 fiscal
years before application.
8. The author suggests each bank plan for implementation now,
and ask all of the following questions EXCEPT:
a. What is your definition of a “small business”?
b. Are you able to identify an application date?
c. Do you have the capabilities to analyze commercial fair lending data?
d. Have you hired enough marketing research staff?
Compliance Audit and Compliance Monitoring:
Better Together Than Apart
By Joseph N. Durham, CRCM, CAMS, and
Paul R. Osborne, CPA, AMLP, CAMS-Audit
9. The author states that in executing the audit plan, internal audit
should account for both the timing and the intensity of:
a. Sales channels.
b. Monitoring efforts.
c. Training classes.
d. IT personnel.
10. The main point of this article is that in today’s regulatory and
operational environment, there needs to be a coordinated
a. Business lines and internal audit.
b. Planning and implementation.
c. Compliance monitoring and Compliance audit.
d. Compliance management and accounting.