CRCM Exam: Proposed Amendment to Regulation Z for Early Disclosure Statement

Compliance Professional's First Step

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Question

The federal banking agencies have proposed an amendment to Regulation Z that would require a new early disclosure statement for loans secured by the borrower's principal dwelling. After reading the proposed change, what should the compliance professional do FIRST?

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Explanations

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A. B. C. D.

C

The proposed amendment to Regulation Z that would require a new early disclosure statement for loans secured by the borrower's principal dwelling is a regulatory change that requires attention from compliance professionals at banks. The first step that a compliance professional should take after reading the proposed change is to thoroughly understand the implications of the amendment on the bank's operations.

Option A, establishing a task force to study the proposed rule, may be premature at this point since the compliance professional has not yet assessed the impact of the proposed change on the bank's operations. However, it may be appropriate to form a task force after the compliance professional has a better understanding of the proposed rule.

Option B, contacting the bank's platform software vendor to determine whether it will be ready for the change, is a valid step, but it should not be the first action taken. Before reaching out to vendors, the compliance professional should first understand the implications of the proposed rule on the bank's operations.

Option C, preparing a summary document that outlines the effects the proposed rule would have on the bank's operations, is a reasonable first step. This summary document can serve as a reference point for the compliance professional and other stakeholders at the bank, and it can help the compliance professional identify the changes that need to be made to the bank's policies and procedures to comply with the proposed rule.

Option D, training bank staff on the new rule, should not be the first action taken. Before training bank staff, the compliance professional should first understand the implications of the proposed rule on the bank's operations and develop a plan to implement the new requirements.

In summary, the compliance professional should start by preparing a summary document that outlines the effects the proposed rule would have on the bank's operations. This document will serve as a reference point for the compliance professional and other stakeholders at the bank, and it can help the compliance professional identify the changes that need to be made to the bank's policies and procedures to comply with the proposed rule.