Worked explanations
The paper carries one for every question, at the back. These are the three above.
Q1
A
Ch. 1: Federal Mortgage Related Laws
Answer: A - Yes - integrating agents and brokers is an express component of the required policies and procedures
Because The policies, procedures and internal controls must include provisions for "integrating the company's agents and brokers into its anti-money laundering program". 31 CFR 1029.210(b)(1)
The compliance officer must also ensure monitoring of "compliance by the company's agents and brokers with their obligations under the program". 31 CFR 1029.210(b)(2)(i)
Where the other options lead
- B.A volume threshold invented. No threshold appears.
- C.Integration denied. It is expressly required.
- D.Employment status made the test. The rule names agents and brokers without distinguishing.
Q2
A
Ch. 1: Federal Mortgage Related Laws
Answer: A - 30 days, unless notice is instead given under the incompleteness procedure in 1002.9(c)
Because Notification is required within "30 days after taking adverse action on an incomplete application, unless notice is provided in accordance with paragraph (c) of this section". 12 CFR 1002.9(a)(1)(ii)
Paragraph (c) is the alternative route: a notice of incompleteness that tells the applicant what is missing and gives a reasonable period to supply it. 12 CFR 1002.9(c)
Where the other options lead
- B.Notice denied. Adverse action on an incomplete application still requires notification.
- C.Disclosure timing imported. Three business days is a Regulation Z deadline.
- D.Counteroffer period imported. Ninety days applies to a lapsed counteroffer.
Q3
D
Ch. 2: Uniform State Content
Answer: D - Yes, it must be able to administer oaths and take and preserve testimony
Because The authority must be able "[t]o administer oaths and affirmations and examine and take and preserve testimony under oath as to any matter in respect to the affairs of any such loan originator". 12 CFR 1008.111(b)(3)
Where the other options lead
- A.Restricts it to hearings. The power runs to investigations as well.
- B.Requires consent. The summons power operates without it.
- C.Reserves oaths to judicial bodies. The regulation requires the authority to have this power.