Alternate Exam Program - When can FDIC alternate exams with state? - Answers -
Alternate Exams can be accepted:
Composite 1-2
Stable and improving 3 (confirmed by SCOR) and no adverse trends
*(length of time between end of one exam and start of next should not exceed 12 to 18
months.)
Who is on the FDIC Board? - Answers -1. Comptroller of the Currency
2. Director of the CFPB
3. 3 appointed by President of US (incl. Chairmen)
a. Individuals who are citizens of US
b. One who shall have State bank
supervisory experience
Not more than three members may be of the same political party
6 yr term / 5 yr. for Chairman
Bank may accept appraisal prepared by an appraiser engaged by another bank, if..... -
Answers -1. Appraiser has no direct or indirect interest in property/transaction
2. The regulated institution determines that the appriasal conforms to requirements of
Part 323 and is acceptable (Appraisal review)
What is the one fundamental & essential attribute all bank directors must possess
without exception? - Answers -Personal Integrity
What does Appendix B to Part 365 do? - Answers -Implement Secure & Fair
Enforcement for Mortgage Licensing Act's (SAFE Act) registration requirement for
mortgage loan originators
SAFE ACt provides (ATCAH)
Aggregating and improving the flow of information between regulators
Providing increased accountability and tracking of mortgage loan originators
, Enhancing Consumer Protections
Supporting anti-fraud measures
Provide consumers employment history, disciplinary history, free and easily accessible
What should bank management do if they are asked to disclose a SAR through
subpoena or otherwise? (PART 353.3) - Answers -Decline to produce SAR or any info
that would disclose that SAR has been prepared or filed using Part 353 as support and
notify FDIC RO
Bank encouraged to file copies of SARs with appropriate State and local authorities
when appropriate
How long must a bank maintain copies of field SARs & supporting info? (Part 353.3) -
Answers -5 years from date of filing (and property of US government).
Timelines for SAR filings? (Part 353.3) - Answers -A SAR must be filed within 30 days
of initial detection of facts warranting SAR
If no suspect identified - timeline can be extended to 60 days.
When does a bank not have to file a SAR? - Answers -Robbery or burglary reported to
law enforcement
Lost, missing, counterfeit, or stolen securities if following proper reporting requirements
to SEC.
When must a bank file a SAR? - Answers -1. Insider abuse involving any amount -
directors, officers, employees, agents, or other IAPs
2. Suspected federal criminal violations of $5M or more where a suspect can be
identified.
3. Suspected federal criminal violations of $25M+ w/o ID of suspect
4. Transactions aggregating $5M or more that involve potential money laundering or
Vios of BSA.
How does FDIC enforce Part 348? (Management Interlock) - Answers -Refers case to
the Attorney General to ensure compliance with Interlocks Act
USA PATRIOT ACT? - Answers -Uniting and Strengthening America by Providing
Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001
According to 326.2, how long does a bank have to develop and administer a written
security program after issued federal deposit insurance? - Answers -180 days
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