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質問 1：
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. As an internal control procedure, require the BSA officer to check the OFAC Web site daily for any changes to the SDN list
B. Conduct compliance audits twice a year
C. Purchase and implement interdiction software for the wire transfer area
D. Routinely provide account transaction information to federal security agencies so suspicious patterns can be detected
正解：C
質問 2：
First National is developing a consumer checking account that can access a line of credit. This is the first time the bank has ever had such a product, although this type of credit facility has been popular with other banks in town. To determine what interest rate to charge on this account, an officer of First National called some of his friends at other local banks offering this type of credit and asked several questions, including the interest rate charged on this type of account and what internal factors the banks use to set the rate. After obtaining this information, First National determines that it could charge approximately 2 percent more than it originally planneD. Is there anything wrong with this course of action?
A. No. The bank could probably have determined the prices eventually without calling the banks directly.
B. No. Communication itself is never wrong regardless of the subject matter.
C. Yes. Communicating with competitors for purposes of setting prices is wrong.
D. Yes. The bank should have disguised its identity in calling its competitors.
正解：C
質問 3：
Which of the following is NOT a requirement when a bank pays an employee a fee for referring a high-net-worth or institutional customer to a broker?
A. The bank must reasonably believe that the customer is a high net worth or institutional customer
B. The bank must give a disclosure to the customer
C. The bank must have a written agreement with the broker
D. The employee must be registered with the bank's regulatory agency
正解：D
質問 4：
According to federal regulations, what must a security officer do when establishing a bank security program?
A. Hire uniformed armed guards to monitor the bank lobby
B. Institute procedures for testing security devices periodically
C. Survey competitors' security procedures
D. Modify the cash vault to meet minimum wall thickness standards
正解：B
質問 5：
The liability of paying and returning banks is subject to the following conditions and limitations EXCEPT:
A. Paying and returning banks agree to indemnify each Reserve Bank for any loss or expense resulting from the paying or returning bank's lack of authorization or any action by a Reserve Bank within the scope of its authority related to the return of the check or any warranty made by the Reserve Bank
B. Regulation CC governs the paying and returning banks' liabilities when returning a substitute check or paper or electronic representation thereof
C. The paying or retuning bank that sends an electronic item that is not a representation of a substitute check will not be liable for losses attributable to the Reserve Bank's own lack of good faith or failure to exercise ordinary care
D. The paying or returning bank that sends an original check that is returned as a substitute check or paper or electronic representation thereof will not be responsible for amounts the Reserve Bank pays under Regulation CC absent the paying bank's or returning bank's agreement to the contrary
正解：A
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. As an internal control procedure, require the BSA officer to check the OFAC Web site daily for any changes to the SDN list
B. Conduct compliance audits twice a year
C. Purchase and implement interdiction software for the wire transfer area
D. Routinely provide account transaction information to federal security agencies so suspicious patterns can be detected
正解：C
質問 2：
First National is developing a consumer checking account that can access a line of credit. This is the first time the bank has ever had such a product, although this type of credit facility has been popular with other banks in town. To determine what interest rate to charge on this account, an officer of First National called some of his friends at other local banks offering this type of credit and asked several questions, including the interest rate charged on this type of account and what internal factors the banks use to set the rate. After obtaining this information, First National determines that it could charge approximately 2 percent more than it originally planneD. Is there anything wrong with this course of action?
A. No. The bank could probably have determined the prices eventually without calling the banks directly.
B. No. Communication itself is never wrong regardless of the subject matter.
C. Yes. Communicating with competitors for purposes of setting prices is wrong.
D. Yes. The bank should have disguised its identity in calling its competitors.
正解：C
質問 3：
Which of the following is NOT a requirement when a bank pays an employee a fee for referring a high-net-worth or institutional customer to a broker?
A. The bank must reasonably believe that the customer is a high net worth or institutional customer
B. The bank must give a disclosure to the customer
C. The bank must have a written agreement with the broker
D. The employee must be registered with the bank's regulatory agency
正解：D
質問 4：
According to federal regulations, what must a security officer do when establishing a bank security program?
A. Hire uniformed armed guards to monitor the bank lobby
B. Institute procedures for testing security devices periodically
C. Survey competitors' security procedures
D. Modify the cash vault to meet minimum wall thickness standards
正解：B
質問 5：
The liability of paying and returning banks is subject to the following conditions and limitations EXCEPT:
A. Paying and returning banks agree to indemnify each Reserve Bank for any loss or expense resulting from the paying or returning bank's lack of authorization or any action by a Reserve Bank within the scope of its authority related to the return of the check or any warranty made by the Reserve Bank
B. Regulation CC governs the paying and returning banks' liabilities when returning a substitute check or paper or electronic representation thereof
C. The paying or retuning bank that sends an electronic item that is not a representation of a substitute check will not be liable for losses attributable to the Reserve Bank's own lack of good faith or failure to exercise ordinary care
D. The paying or returning bank that sends an original check that is returned as a substitute check or paper or electronic representation thereof will not be responsible for amounts the Reserve Bank pays under Regulation CC absent the paying bank's or returning bank's agreement to the contrary
正解：A
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