CRCM practice question 6 of 35

In a compliance program, tactical compliance procedures should be integrated into business line procedures, such as how to deliver an Adverse Action Notice when an application is declined. In this case:

Full set: 459 questions
Answer options
A: Regulations should be applied consistently to procedures throughout the bank
B: Revisions to procedures should be based on compliance expertise and not mere editing
C: Providing solutions to mitigate any identified risk
D: Assisting business units in developing or revising policies and procedures to reflect current regulatory requirements Correct answer
Correct Answer:
D. Assisting business units in developing or revising policies and procedures to reflect current regulatory requirements
Explanation

The integration of tactical compliance procedures into business line operations is a core function of the compliance department. This involves actively collaborating with and assisting business units to ensure their day-to-day procedures are developed or revised to be fully compliant with current regulations. This proactive partnership is fundamental to embedding compliance into the bank's culture and operations. Options A and B are principles that guide this work, but D describes the foundational activity itself.

Why Incorrect

A: This is a correct principle, but it's a quality of the outcome, not the description of the integration activity itself, which is what D describes. B: This is a valid point for revisions, but D is a broader and more foundational description of the compliance function's role in the entire process. C: This describes the ultimate goal (risk mitigation) of the procedures, not the process of integrating them.

References

1. Office of the Comptroller of the Currency (OCC). (2023, October). Comptroller's Handbook: Corporate and Risk Governance. Section: "Independent Risk Management," pp. 21-22. The handbook states that independent risk management (which includes compliance) is responsible for "providing ongoing assistance and guidance to business lines" and "assisting in the development and revision of policies and procedures."

2. Board of Governors of the Federal Reserve System. (2008). SR 08-8: Compliance Risk Management Programs and Oversight at Large Banking Organizations with Complex Compliance Profiles. Attachment, p. 6. This guidance notes that a key role of the corporate compliance function is to "assist in the development of business-line compliance policies and procedures."

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