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Certified Regulatory Compliance Manager Practice Test

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A compliance manager's responsibilities generally include direct compliance risk program management and/or validation of compliance risk control effectiveness. The execution of operational business processes incorporating compliance risk controls is not a function or duty generally performed by a compliance manager as a normal and customary job responsibility and thus does not qualify towards meeting the experience requirement.

To satisfy the Professional Experience requirement- primary responsibility for the full range of compliance risk functions is required. Compliance risk functions include- but are not limited to:

Performing compliance risk assessments- audits or examinations- or Developing- implementing- and/or managing all aspects of a compliance risk management program to ensure compliance with U.S. federal laws and regulations.
These jobs are typically found within corporate compliance- legal- audit departments (internal or external)- Regulatory Agencies- or dedicated compliance practices within consulting firms. Job responsibilities must be primarily focused on compliance risk management:

Program design- implementation and oversight- Consultation as a subject-matter expert- Administration- enforcement or audit of compliance-related policies- procedures and processes to manage compliance risk- and/or Examination of a bank's compliance program.

Task 1: Act as a compliance subject matter expert on projects and committees.
Task 2: Evaluate development of- or changes to- products- services- processes- and systems to determine compliance risk and impacts and ensure policies remain compliant.
Task 3: Provide compliance support to internal and external parties (e.g.- answer questions- review marketing and external communications- conduct research and analysis).
Task 4: Review and/or provide compliance training to applicable parties.
Task 5: Participate in conducting due diligence for vendors.
Task 6: Design and maintain a comprehensive compliance risk assessment program to identify and mitigate risk within the organizations risk appetite.
Task 7: Conduct compliance risk assessments in accordance with the risk assessment program to evaluate relevant information (e.g.- inherent risk- control environment- residual risk- potential for consumer harm) and communicate results to applicable parties.

The following knowledge is required to perform the tasks within Domain 1:
• All applicable laws- regulations- and guidance
Other essential CRCM knowledge:
• Risk assessment program scope and objectives
• Compliance risk appetite (e.g.- thresholds- escalation points- pass/fail rates)
• Banks products- services- processes- market area- and operations
• Regulatory and industry landscape
• Risk rating methodology
• Key risk indicators (KRIs)
• Volume and severity of known compliance incidents- breakdowns- and/or customer complaints
• Compliance policies- procedures- and other internal controls (e.g.- quality assurance- independent testing)
• Exam/audit and internal compliance monitoring results
• Volume and complexity of products- transactions- and customer base
• latest changes to compliance regulations- key personnel- products- services- systems- and/or processes
• Volume and complexity of products and services provided by third parties

Domain 2: Compliance Monitoring (25%)
Task 1: Define the scope of a specific monitoring or testing activity.
Task 2: Test compliance policies- procedures- controls- and transactions against regulatory requirements to identify risks and potential exceptions.
Task 3: Review and confirm potential exceptions- findings- and recommendations with business units and issue final report to senior management.
Task 4: Validate that any required remediation was completed accurately and within required timelines.
Task 5: Administer a complaint management program.
Task 6: Review first line compliance monitoring results and develop an action plan as needed.
Task 7: Evaluate the reliability of systems of record and the validity of data within those systems that areused for compliance monitoring.

The following knowledge is required to perform the tasks within Domain 2:
• All applicable laws- regulations- and guidance.
Other essential CRCM knowledge:
• Regulator expectations
• Banks products- services- processes- market area- and operations
• Compliance policies- procedures- and controls
• Applicable source data
• Target audience
• Compliance risk rating methodology
• Compliance risk appetite (e.g.- thresholds- escalation points- pass/fail rates)
• Complaints received internally and externally- including volumes- sources- trends- and root causes
• Regulatory expectations on complaint management program administration
• Complaint handling procedures
• Critical systems and usage by the business units
• latest changes to critical systems or processes

Domain 3: Governance and Oversight (10%)
Task 1: Establish and maintain a compliance management policy to set expectations for board- senior management- and business unit responsibilities.
Task 2: Develop- conduct- and track enterprise-wide and/or job-specific compliance training.
Task 3: Conduct periodic reviews of the compliance management program to evaluate its effectiveness and communicate results to appropriate parties.
The following knowledge is required to perform the tasks within Domain 3:
• Regulatory expectations
• Compliance risk appetite (e.g.- thresholds- escalation points- pass/fail rates)
• Banks products- services- processes- and operations
• Employee roles and responsibilities
• Compliance risk assessment results
• Regulatory change environment
• Compliance monitoring results
• Compliance audit/exam findings
• Compliance management policy (CMP)
• Volume and severity of known compliance incidents- breakdowns- and/or customer complaints

Domain 4: Regulatory Change Management (15%)
Task 1: Monitor and evaluate applicable regulatory agency notifications for new compliance regulations or changes to existing regulations to assess potential regulatory impacts and remediation needs.
Task 2: Assess new- revised- or proposed regulatory changes for compliance impacts- communicate to the appropriate parties- and develop action plans as needed.
Task 3: Assess regulatory guidance and compliance enforcement actions to determine if remediation is required to address potential compliance impacts.
Task 4: Report on the status of regulatory changes and implementation to appropriate parties.
Task 5: Monitor and validate action plans for confirmed regulatory impacts to ensure timely adherence to the mandatory compliance date.
The following knowledge is required to perform the tasks within Domain 4:
• All applicable laws- regulations- and guidance.
Other essential CRCM knowledge:
• Banks products- services- processes- market area- and operations
• Key stakeholders
• Timeline and extent of impact to business units
• Planned changes to critical systems
• New or revised compliance policies- procedures- controls- and training
• Changes to banks products- services- processes- market area- and operations
• Penalties and potential restitution for non-compliance
• Scope of impacts

Domain 5: Regulator and Auditor Compliance Management (11%)
Task 1: Prepare and review requested audit/exam materials to ensure timely and accurate fulfillment and self-identify potential areas of concern.
Task 2: Participate in audit/exam meetings to provide business overviews- address questions- discuss findings- or provide updates to appropriate parties.
Task 3: Review and draft responses to audit/exam results and ensure action plans are developed and communicated to appropriate parties.
Task 4: Report on action plan status to appropriate levels of management and auditors/examiners.
Task 5: Coordinate and submit ongoing regulatory reports to auditors/examiners.
The following knowledge is required to perform the tasks within Domain 5:
• All applicable laws- regulations- and guidance.
Other essential CRCM knowledge:
• Banks products- services- processes- market area- and operations
• Key stakeholders
• Compliance policies- procedures- and controls
• Critical systems and usage by the business units
• Services provided by third parties
• Compliance risk appetite (e.g.- thresholds- escalation points- pass/fail rates)
• Effectiveness of actions taken
• Regulatory expectations
• Top risk- emerging risk- and areas of continued focus
• New bank products- services- processes- market area- and operations

Domain 6: Compliance Analysis and Internal/External Reporting (11%)
Task 1: Analyze and validate data to support regulatory reporting and ensure accuracy and comprehensiveness.
Task 2: Complete required reporting- ensure timely submission to the appropriate agency- and resubmit when required.
Task 3: Develop- implement- and monitor a plan of action to prevent future reporting errors or breakdowns.
The following knowledge is required to perform the tasks within Domain 6:
• CRA
• HMDA
• BSA (CTR- SARS)
• OFAC
• Regulation Z (Credit card agreements- marketing on college campuses)
• Regulation II
• Banks products- services- processes- market area- and operations
• Critical systems and usage by the business units
• Findings and root causes
• Compliance policies- procedures- and controls
• Regulator expectations
• Compliance risk appetite (e.g.- thresholds- escalation points)
• Penalties and potential restitution for non-compliance
• Scope of impacts

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Certified Regulatory Compliance Manager
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QUESTION: 445
An individual comes into the bank and makes a $6,000 cash deposit into a checking
account. At the same time, the individual buys a $7,000 cashier�s check with cash.
According to the Bank Secrecy Act, what is the bank is required to do?
A. File a SAR for $13,000
B. File a CTR for the $6,000 cash deposit
C. Aggregate the transactions and retain information about the purchase of the cashier�s
check
D. Obtain the recordkeeping information for the purchase of the cashier�s check and
complete a CTR for the total cash-in transaction of $13,000
Answer: D
QUESTION: 446
Which of the following is NOT considered an acceptable form of identification for an
individual when completing a CTR?
A. U.S. passport
B. Long-term deposit account relationship
C. State-issued photo identification (e.g., driver�s license)
D. Photo identification card issued by a local government agency
Answer: B
QUESTION: 447
Which of the following customers may be exempted under Phase II of the Bank Secrecy
Act?
A. Government agencies
B. Correspondent banks
C. Payroll customers
D. Businesses whose stocks are traded on a national stock exchange
Answer: C
QUESTION: 448
In which of the following circumstances is it LEAST appropriate for a bank to file a SAR
regarding Internet activity?
A. Bank determines that one of its customers is the victim of identity theft
156
B. Bank becomes aware of identity theft of its domain name (i.e., another entity selects a
name similar to the bank�s in order to confuse customers and obtain confidential financial
information)
C. Bank discovers that someone has hacked into its data system in order to obtain
confidential customer data
D. Bank determines through its transaction-monitoring program that a customer is
making electronic transfers between his own checking and savings accounts that are just
below the $10,000 reporting level
Answer: D
QUESTION: 449
When completing and filing a SAR, what is the bank NOT required to do?
A. Submit a copy of the supporting documentation with the SAR
B. Submit the SAR within 30 days of the initial detection of facts
C. Report the SAR information to the bank�s board of directors
D. Maintain a copy of the SAR and supporting documentation for 5 years
Answer: A
QUESTION: 450
What should a bank�s Bank Secrecy Act compliance program include?
A. All lobby notice requirements
B. The one-year record retention requirements
C. Designation of individuals responsible for day-to-day compliance
D. A list of types of loans covered by the Act
Answer: C
QUESTION: 451
A routine review of account records reveals that suspicious activity involving foreign
currency has occurred in the account of one of the bank�s directors. Which of the
following actions should be taken FIRST?
A. A SAR should be filed.
B. The bank�s board of directors should discuss the account activity without the affected
director being present.
157
C. The bank�s president should meet with the affected director to discuss the account
activity.
D. The bank should file a CTR, checking the box that indicates the report is for
suspicious activity.
Answer: A
QUESTION: 452
A compliance officer is constructing a review of a transaction in which M, a deposit
account customer, used cash to purchase travelers� checks in an amount of $4,000. The
compliance officer must determine compliance with financial recordkeeping and
currency reporting regulations. Which of the following pieces of information must be part
of the bank�s records for this transaction?
A. M�s date of birth
B. M�s deposit account number
C. The serial numbers of the travelers� checks purchased
D. The name of the branch where the transaction occurred
Answer: C
QUESTION: 453
When all the required information is NOT provided by a person purchasing a cashier�s
check with $8,000 in currency, what should the bank do?
A. Refuse the transaction
B. Complete the transaction and record available information
C. Complete the transaction and file a SAR
D. Complete the transaction and insist that the customer return with the required
information
Answer: A
QUESTION: 454
Which of the following is MOST effective in strengthening an anti-money laundering
program involving cash transactions?
A. Review all deposits of $25,000 or more
B. Complete CTR worksheets on all cash transactions of $5,000 or more
C. Complete SAR worksheets on all cash transactions of $5,000 or more
D. Monitor cash transactions of less than $10,000 for suspicious patterns
158
Answer: D
QUESTION: 455
For which of the following is a bank most likely to be in danger of receiving a cease and
desist order?
A. Repetition in a BSA examination of a noncritical deficiency reported in a previous
BSA examination
B. Failure to document AML training to its part-time clerical employees
C. A 2 percent error rate on the bank�s CTRs
D. Failure to file suspicious activity reports
Answer: D
QUESTION: 456
Which of the following countries are currently subject to the Office of Foreign Assets
Control Regulations?
A. North Korea
B. Jordan
C. Bahrain
D. Russia
Answer: A
QUESTION: 457
What should a bank do when it receives a request from a customer to transfer funds to an
individual in Iraq?
A. Conduct the transfer as requested
B. Conduct the transfer if the individual and the financial institution are not on the SDN
list
C. Block the transfer
D. Conduct the transfer and then notify OFAC immediately
Answer: B
QUESTION: 458
159
ACME Bank is a $600 million institution with 15 branches within three counties.
Because of its proximity to Mexico, the bank has many foreign national customers and
makes many foreign wire transfers for its customers. Currently the bank�s branch
managers print the OFAC list of SDNs and place them in strategic places in each branch.
The wire transfer department keeps its own copy of the list. The compliance officer has
implemented an annual auditing program to check the bank�s compliance with OFAC
regulations. The findings of this audit are provided to the bank�s board of directors
annually. The bank�s regulatory agency has indicated to management that the bank has a
high risk for BSA/AML/OFAC compliance. Of the following actions, which would be
the most effective to strengthen the bank�s OFAC compliance?
A. Conduct compliance audits twice a year
B. Purchase and implement interdiction software for the wire transfer area
C. As an internal control procedure, require the BSA officer to check the
OFAC Web site daily for any changes to the SDN list
D. Routinely provide account transaction information to federal security agencies so
suspicious patterns can be detected
Answer: B
QUESTION: 459
State National Bank is a $250 million community bank. It makes a variety of consumer
and commercial loans, regularly transmits funds via wire transfers for its customers, and
issues commercial and stand-by letters of credit. Which of the following transactions can
State National make without checking the OFAC SDN list and without incurring
liability?
A. Send a wire transfer via its correspondent bank in New York for a commercial
customer.
B. Sell a cashier�s check payable to a third party.
C. Cash an on-us check over-the-counter for a noncustomer.
D. None. The bank can be liable for all.
Answer: D
QUESTION: 460
FA presents cash to the bank and seeks to wire it to his spouse, RA, in CubA. The OFAC
list identifies RA as a specially designated national. Under OFAC Regulations, what
should the bank do?
A. Block the transfer
B. Conduct the transfer as requested and take no further action
160
C. Conduct the transfer as requested and notify OFAC immediately
D. Conduct the transfer only if the bank determines that Cuba is not a blocked country
Answer: A
QUESTION: 461
Your institution has identified a transaction by an existing depositor that should be
blocked under OFAC requirements. The branch manager contacts you for specific
instructions. Before reporting the transaction to OFAC, what should the bank do?
A. Reject the transaction
B. Process the transaction
C. Close the customer�s account
D. Place the funds in an interest-bearing account
Answer: A
QUESTION: 462
Your bank�s president comes back from an industry conference and tells the compliance
officer that she attended a presentation about OFAC. She heard the bank could be fined
for not adhering to OFAC requirements. Thus, she has directed that every bank
transaction be reviewed for OFAC compliance. What is the most appropriate statement
the compliance officer could make to the bank president?
A. The bank is already in compliance because OFAC checks are performed on all new
depositors
B. The bank has assessed its OFAC risk and has implemented risk-based OFAC
procedures
C. OFAC does not apply because the bank does not conduct business in foreign countries
or with foreign nationals
D. Banks are usually not fined for OFAC violations unless they conduct transactions with
SDNs or blocked countries
Answer: B
QUESTION: 463
The BSA officer has just been notified by the chief operations officer that, due to a glitch
in the bank�s OFAC interdiction software, wires have been regularly transmitted to a
bank on the SDN list. Based on the OFAC Enforcement Guidance, what should the BSA
Officer do FIRST to attempt to mitigate any penalties?
161
A. Review the OFAC wire policies and procedures to determine how the errors occurred
B. Stop and hold all wires to the bank on the SDN list
C. Investigate the customer who sends these wires
D. Self-report the activity to OFAC
Answer: B
162
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