ABA Bank Compliance - March/April 2010

CRCM Certified Regulatory Compliance Manager

The CE quizzes in ABA Bank Compliance magazines provide up to six continuing education credits per year to Certified Regulatory Compliance Managers (CRCMs). Each quiz consists of 10 questions taken directly from the articles in each issue and have been pre-approved by the ICB for 1.0 credit per quiz. You must correctly answer seven out of the 10 questions to receive the credit.

To take the quiz, please go to www.icbmembers.org, login, and click on “Continuing Education Quizzes (ABA Magazine)” located on the left-hand side of the page. Once you have completed the quiz, you will receive immediate notification of the results, which can be printed and saved for your records. Quiz credits are automatically uploaded to your record and will show under “My Continuing Education Credits” within 48 hours. If you have any questions, contact ICB’s Continuing Education Manager at icb@aba.com.

Reverse Mortgages: What to Consider Before Developing, Marketing, and Originating Them

By Phillip R. “Rick” Freer, CRCM, and Calvin R. Hagins, CRCM, CRP, AMLP

1. In a speech before the ABA Regulatory Compliance Conference in 2009, Comptroller of the Currency John C. Dugan said reverse mortgages should set off alarm bells because they share a lot of the same characteristics as the riskiest types of:

a. subprime mortgages a. home equity lines of credit a. personal loans secured by homes a. home equity conversion mortgages

2. Because the lender is basing the loan on the value of the underlying collateral (the property), borrower credit scores and credit history are:

a. more important than with traditional mortgages a. less important than with traditional mortgages a. equally important as with traditional mortgages a. not taken into consideration at all

3. Which of the following is NOT a pitfall of a reverse
mortgage product?
a. the costs are higher than other mortgage products
b. terms may vary
c. consumers lose the titles to their homes
d. consumers can become confused and unsure what
they are purchasing

Hijacked! Defending Your Corporate Customers By Doug Johnson, Bill Nelson, and Michael Herd

4. According to the FDIC, the most prevalent of the
many money mule schemes is:
a. online job postings used by criminals seeking work-
from-home candidates
b. advance fee scans
c. mystery shopping jobs
d. use of social networking as a recruitment tool

5. The FBI believes that as of October 2009 there had been about how much in attempted fraud through hijacking of corporate accounts?

a. $50 million b. $100 million c. $150 million d. $200 million

6. If one of your bank’s business customer’s accounts
is hijacked and unauthorized ACH transactions are
completed, what is the first thing you should do?
a. File a police report
b. Contact the receiving depository institution to
determine whether the funds have been withdrawn
c. File a suspicious activity report
d. Conduct a forensic analysis and consider suspending
the victimized business’s funds transfer ability

Monitoring Fair Lending with Brokered Loans

By Melanie Hibbs Brody and Richard R. Pace

7. What 2003 U.S. Supreme Court case issued a decision stating that the Fair Housing Act does not impose a nondelegable duty on persons to ensure that the parties with whom they do business do not discriminate?

a. Jeffries v. Wells Fargo Bank, N.A., et al. b. Zamora v. Wachovia Corporation c. Meyer v. Holley d. Miller, et al. v. Countrywide Bank, N.A., et al.

8. In 1996, the Department of Justice settled retail and wholesale price discrimination claims against which bank, marking the first major wholesale pricing settlement with an unprecedented $3 million in compensation to alleged victims?

a. Long Beach Bank, FSB b. Delta Funding Corporation c. Countrywide Home Loans, Inc. d. Gateway Funding, Inc.

Navigating TARP Funding By William W. Rudolph

9. To bring transparency to TARP and help prevent, detect,
and respond to waste, fraud, or abuse of TARP funds, the
Emergency Economic Stabilization Act (EESA) created
this oversight entity, naming Neil Barofsky to lead it:
a. TARP Inspector General Council (TARP-IGC)
b. Office of the Special Inspector General for the Troubled
Asset Relief Program (SIGTARP)
c. Private-Public Investment Program
d. Congressional Oversight Committee

10. As of January 30, 2010, the Office of the Special Inspector General of the Troubled Asset Relief Program reported how many “active” investigations “involving both criminal and civil matters?”