CRCM practice question 12 of 35

Debt Cancellation Contracts and Debt Suspension Agreements coverage includes:

Full set: 459 questions
Answer options
A: National banks that issue debt cancellation contracts and debt suspension agreements with borrowers in connection with loans for personal, family, or household purposes Correct answer
B: A national bank may not engage in any practice, including advertising, which would cause a reasonable person to be misled with respect to DSAs and DCCs
C: A bank must provide the long-form disclosures in writing before the customer completes the purchase of a contract. If the solicitation occurs in person, the long-form disclosures must be provided at that time
D: A bank must make the short-form disclosures orally at the time the bank first solicits the contract
Correct Answer:
A. National banks that issue debt cancellation contracts and debt suspension agreements with borrowers in connection with loans for personal, family, or household purposes
Explanation

The question asks what the "coverage" of the Debt Cancellation Contracts (DCCs) and Debt Suspension Agreements (DSAs) regulation includes. The most accurate answer is the one that defines the scope of the rule. The Office of the Comptroller of the Currency (OCC) rule, 12 CFR Part 37, applies specifically to national banks and federal savings associations. The rule's scope is further defined to cover DCCs and DSAs offered in connection with loans made for personal, family, or household purposes. This statement accurately describes the entities and transactions covered by the regulation.

Why Incorrect

B. A national bank may not engage...: This describes a specific prohibited practice under the rule, not the overall scope or coverage of the regulation itself.
C. A bank must provide the long-form disclosures...: This is a specific disclosure requirement within the rule, not a definition of the rule's coverage.
D. A bank must make the short-form disclosures orally...: This is an inaccurate oversimplification; oral disclosure is required for telephone solicitations, not all initial solicitations.

References

1. Office of the Comptroller of the Currency. (2021). 12 CFR Part 37 - Debt Cancellation Contracts and Debt Suspension Agreements. Section 37.2(a) "Scope" and Section 37.1(c) "Consumer."

2. Office of the Comptroller of the Currency. (2002, January 17). OCC Bulletin 2002-2, Debt Cancellation Contracts and Debt Suspension Agreements: Final Rule. Subject: Description of the Final Rule.

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