IIA-CIA-PART3-3P practice question 12 of 35

Which of the following activities most significantly increases the risk that a bank will make poor- quality loans to its customers?

Full set: 488 questions
Answer options
A: Borrowers may not sign all required mortgage loan documentation.
B: Fees paid by the borrower at the time of the loan may not be deposited in a timely manner.
C: The bank's loan documentation may not meet the government's disclosure requirements.
D: Loan officers may override the lending criteria established by senior management. Correct answer
Correct Answer:
D. Loan officers may override the lending criteria established by senior management.
Explanation

The quality of a loan is determined by the borrower's ability and willingness to repay, which is assessed during the underwriting process. Senior management establishes lending criteria (e.g., credit scores, debt-to-income ratios, collateral requirements) as a primary control to manage credit risk and ensure loans are made only to qualified applicants. When loan officers override these established criteria, they are bypassing the fundamental controls designed to prevent lending to high-risk borrowers. This action directly and significantly increases the likelihood of originating poor-quality loans that may result in default, which is the most severe risk among the options provided.

Why Incorrect

A. This is a documentation and legal risk. While it can create issues with enforcing the loan agreement, it does not inherently mean the borrower is not creditworthy.
B. This is an operational risk related to fee collection and processing. It affects the bank's income recognition but has no bearing on the credit quality of the loan itself.
C. This is a compliance risk. Failure to meet disclosure requirements can lead to regulatory penalties and legal action but does not directly impact the borrower's ability to repay the loan.

References

1. Basel Committee on Banking Supervision. (2000, September). Principles for the Management of Credit Risk. Bank for International Settlements. Principle 5, "Operating under a sound credit granting process," states, "Banks must operate within the parameters of well-defined credit-granting criteria. These criteria should include a clear indication of the bank’s target market and a thorough understanding of the borrower..." (p. 10, para. 24). Overriding these criteria directly violates this core principle.

2. The Institute of Internal Auditors. (2017). International Standards for the Professional Practice of Internal Auditing (Standards). Standard 2120.A1 requires internal audit to "evaluate risk exposures relating to the organization’s governance, operations, and information systems regarding the... achievement of the organization’s strategic objectives." A bank's strategic objective includes maintaining a sound loan portfolio, which is jeopardized when lending criteria are overridden.

3. Bessis, J. (2015). Risk Management in Banking (4th ed.). Wiley. In Chapter 13, "Credit Risk Management," the author emphasizes that the credit decision process relies on defined policies and standards. "Exceptions to policies should be documented and authorized at a higher hierarchical level," highlighting that unauthorized overrides are a major control failure that directly impacts loan quality.

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