Compliance Ratings Defs

Question 1

Compliance mgmt system is strong

Answer 1

1

Question 2

CMS is satisfactory

Answer 2

2

Question 3

CMS is deficient

Answer 3

3

Question 4

CMS is seriously deficient

Answer 4

4

Question 5

CMS is critically deficient

Answer 5

5

Question 6

assigned to financial institutions that maintain a strong CMS

Answer 6

1

Question 7

assigned to a financial institution that maintains a CMS that is satisfactory at managing con­sumer compliance risk in the institution’s products and services

Answer 7

2

Question 8

take action to prevent violations and consumer harm

Answer 8

1

Question 9

substantially limiting violations of law and consumer harm.

Answer 9

2

Question 10

CMS deficient at managing con­ sumer compliance risk in the institution’s products and services and at limiting violations of law and consumer harm.

Answer 10

3

Question 11

CMS seriously deficient at manag­ ing consumer compliance risk in the institution’s products and services and/or at preventing violations of law and consumer harm.

Answer 11

4

Question 12

indicates funda­ mental and persistent weaknesses in crucial CMS ele­ ments and severe inadequacies in core compliance areas necessary to operate within the scope of statutory and regulatory consumer protection requirements and to pre­ vent consumer harm.

Answer 12

4

Question 13

CMS critically deficient at manag­ ing consumer compliance risk in the institution’s products and services and/or at preventing violations of law and consumer harm.

Answer 13

5

Question 14

indicates an ab­ sence of crucial CMS elements and a demonstrated lack of willingness or capability to take the appropriate steps necessary to operate within the scope of statutory and regulatory consumer protection requirements and to pre­ vent consumer harm.

Answer 14

5

Question 15

what are the three categories of the CC rating system?

BCV

Answer 15

Board and Mgmt Oversight

Compliance Program

Violations of Laws and Consumer Harm

Question 16

• self-identification of consumer compliance issues and corrective action undertaken as such issues are identified.

Answer 16

Board and Mgmt Oversight assessment factor

Question 17

• oversight of and commitment to the institution’s CMS;

Answer 17

Board and Mgmt Oversight assessment factor

Question 18

• effectiveness of the institution’s change management processes, including responding timely and satisfactorily to any variety of change, internal or external, to the insti­ tution;

Answer 18

Board and Mgmt Oversight assessment factor

Question 19

• comprehension, identification, and management of risks arising from the institution’s products, services, or activi­ ties;

Answer 19

Board and Mgmt Oversight assessment factor

Question 20

• whether the institution’s policies and procedures are ap­ propriate to the risk in the products, services, and activi­ ties of the institution;

Answer 20

Compliance Program – Assessment Factors

Question 21

• the degree to which compliance training is current and tailored to risk and staff responsibilities;

Answer 21

Compliance Program – Assessment Factors

Question 22

• the sufficiency of the monitoring and, if applicable, audit to encompass compliance risks throughout the institution;

Answer 22

Compliance Program – Assessment Factors

Question 23

• the responsiveness and effectiveness of the consumer complaint resolution process.

Answer 23

Compliance Program – Assessment Factors

Question 24

• the root cause, or causes, of any violations of law identi­fied during the examination;

Answer 24

Violations of Law and Consumer Harm – Assessment Factors

Question 25

• the severity of any consumer harm resulting from viola­tions;

Answer 25

Violations of Law and Consumer Harm – Assessment Factors

Question 26

• the duration of time over which the violations occurred; and

Answer 26

Violations of Law and Consumer Harm – Assessment Factors

Question 27

• the pervasiveness of the violations.

Answer 27

Violations of Law and Consumer Harm – Assessment Factors

Question 28

An institution in this group has an outstanding record of helping to meet the credit needs of its assessment area, including low- and moderate income neighborhoods, in a manner consistent with its resources and capabilities.

Answer 28

CRA - Outstanding (O)

Question 29

An institution in this group has a satisfactory record of helping to meet the credit needs of its assessment area, including low- and moderate income neighborhoods, in a manner consistent with its resources and capabilities.

Answer 29

CRA - Satisfactory (S)

Question 30

An institution in this group needs to improve its overall record of helping to meet the credit needs of its assessment area, including low and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.

Answer 30

CRA - Needs to Improve (N)

Question 31

An institution in this group has a substantially deficient record of helping to meet the credit needs of its assessment area, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.

Answer 31

CRA - Substantial Noncompliance (SN)