Compliance Management System & Policy Writing

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Question 1 of 10

1. Question
1. Which role is primarily responsible for the Oversight component of a Compliance Management System?
A. Compliance Officer.
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B. Chief Compliance Officer.
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C. Chief Executive Officer.
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D. Board of Directors.
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Question 2 of 10

2. Question

Which option best reflects the roles that are intended to benefit from the Training & Communication component of a Compliance Management System?

A. Customers and third parties.
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B. Board of Directors.
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C. Management and personnel.
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D. All the above.
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Question 3 of 10

3. Question
1. Which Compliance Management System Component is expected to demonstrate to examiners that the Board of Directors and appropriate delegates comprehend the various compliance risks and can identify and manage those risks?
A. Oversight.
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B. Program Documentation.
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C. Investigations.
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D. Continuous Improvement.
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Question 4 of 10

4. Question
1. [Select the option that best fills in the blank.] The _____________ Component of a Compliance Management System is expected to demonstrate to examiners that the institution maintains an effective mechanism to review internal and external deficiencies, consumer complaints, internal violations, and third-party issues.
A. Investigations.
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B. Continuous Improvement.
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C. Training and Communications.
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D. Monitoring, Testing, Auditing.
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Question 5 of 10

5. Question
1. Which of the following options lists each of the key elements of an effective written policy?
A. Oversight, Program Documentation, Training & Communication, Monitoring, Testing, Auditing, Investigations, Response to Violations, Continuous Improvement.
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B. Title, Change Management, Monitoring, Auditing, Testing, Communications, Destruction of Records, and Additional Requirements.
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C. Title, Scope, Purpose, Responsibility, Change Management, Audit, Training, Record Retention, and Additional Information.
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D. None of the above.
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Question 6 of 10

6. Question
1. The Training element of an effective written policy includes the following information:
A. A hyperlink to the institution’s Learning Management System (LMS).
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B. The system that will ensure comprehensive, role-specific, and timely training; the education and experience requirements of relevant individuals; periodic assessment of knowledge and comprehension of policy subject matter; and remedial training requirements.
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C. Training is not an essential element of an effective written policy.
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D. The institution’s commitment that all relevant personnel will receive appropriate training.
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Question 7 of 10

7. Question
1. [Scenario] The institution received a Best Practice comment in its recent Regulation B Policy review indicating that it should consider revising its Policy Statement to enhance the effectiveness of the policy. The institution’s current policy statement provides, “Institution of Anywhere intends to comply with Regulation B.” Which of the following options appears to offer the most effective resolution?
A. Copy and paste a policy statement from a template Regulation B policy and check this off the list.
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B. Revise the policy statement to, “Institution of Anywhere intends to comply with Regulation B and the Equal Credit Opportunity Act (ECOA),” and check this off the list.
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C. Ignore the Best Practice comment because it is not a Requirement.
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D. Consider the purpose of the policy; review viable options from external resources; modify the statement to appropriately reflect the institution’s purpose; submit the revised policy to a third-party for review; and finally, ensure the Board of Directors reviews and approves the policy at least annually.
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Question 8 of 10

8. Question
1. [Scenario] The institution received a Best Practice comment in its recent Lending Policy review indicating that it should consider removing or revising the current zero-tolerance statement to allow for certain exceptions. The current policy states, “Any deviation from or violations of this Policy will result in disciplinary action up to and including termination.” Which of the following options appears to offer the most appropriate considerations when revising the zero-tolerance statement?
A. Consider the possible exceptions that may arise under each area of the Lending Policy; craft a statement notifying personnel of the role(s) responsible for approving policy exceptions; incorporate the general guidelines or criteria for making safe and sound policy exceptions; and incorporate recordkeeping requirements appropriate for the type of exception(s) under consideration.
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B. Consider submitting the policy to another third party to get a second opinion as to whether an exception to the Lending Policy would be permitted.
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C. Consider the possible exceptions that may arise under each area of the Lending Policy; copy and paste a statement from a template policy; and send it to the Board of Directors for review and approval.
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D. Ignore the Best Practice comment because it is not a Requirement.
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Question 9 of 10

9. Question
1. Which of the following is a common policy issue?
A. Using specific names for responsibilities.
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B. Including zero-tolerance statements.
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C. Outdated policy information.
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D. All the above.
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Question 10 of 10

10. Question

Which of the following options lists the most appropriate third parties that an institution may rely on to help craft, revise, review, and/or improve its written policies?

A. Auditors, examiners, supervisory agencies, the Department of Justice (DOJ), and the Conference of State Bank Supervisors (CSBS).
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B. Compliance Consultants, RegTech, Legal Counsel, Industry Associations, and Third-Party Training.
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C. Regulatory Technology is sufficient to ensure the institution maintains an effective and tailored policy for its size, sophistication, complexity, and other key factors.
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D. Third parties are often unnecessary to craft effective policies.
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