Make Training a Game
by Mary Beth Guard, BOL Guru
The next time your institution conducts a compliance training session for employees, consider incorporating a game for a fun way to test compliance knowledge.
Compliance Jeopardy, for example, is easy to play. You determine what you want the categories to be. You devise five questions under each category, in increasing levels of difficulty, and you print each question up in large type on a single sheet of paper. On a separate sheet placed on top of the question, you indicate the point or dollar value of the question.
Divide the attendees into two teams. Use a timer to allot three minutes per question. Rather than following the tv game show rules, where the correctly-answering player is allowed to continue answering one question after another, I suggest you rotate between the teams. If a team fails to answer a question correctly, it is passed to the other team, who has the opportunity to answer that question and the next (their normal question). A team selects a question by naming the category and the dollar or point amount. Keep score and award small, fun prizes at the end.
Write your own questions, or use the ones I've supplied below. I've created fifteen questions for lending and fifteen for operations. Remember, answers should be phrased in the form of a question!
Loan Compliance Jeopardy
1. Loan Disclosures/Notices
3. Coverage Issues
Category: Loan Disclosures/Notices
Amount of time a consumer has to rescind a transaction secured by his principal dwelling.
(two part answer!)
Answer: The correct answer is "What is three business days?" For extra points, the team can supply the second part of the answer, which is "What is up to three years if disclosures are not given correctly?"
For a loan to require early TIL disclosures, it must be covered by Reg Z and RESPA and be _______.
Answer: "What is a Residential Mortgage Transaction?"
This must be completed on virtually any loan secured by improved RE.
Answer: "What is a Standard Flood Hazard Determination Form?"
A copy of an appraisal (or notice of right to receive one) must be given on loans secured by this type of collateral.
Answer: "What is a dwelling?"
Requires a consumer's written acknowledgement of receipt (3 possible correct answers)
Answer: "What are the consumer protection insurance disclosures?"
"What is the mortgage servicing history disclosure?"
"What is the notice of flood hazard?"
Category: Coverage Issues
Prohibits discrimination on the basis of familial status or disability.
Answer: "What is the Fair Housing Act?"
What you must ask for on an application for home purchase or refinance [if your institution is covered by HMDA].
Answer: "What is government monitoring information?"
Type of loan on which you should not request government. monitoring information.
Answer: There are lots of correct answers to this one. For example "What is a car loan?" (Basically, anything not covered by Regulation B's Section 202.13 or HMDA would work for an answer.)
If the applicant is individually creditworthy, you cannot require this.
Answer: "What is a co-signer or guarantor?"
You can never require ____________ to be a guarantor or cosigner.
Answer: "What is the applicant's spouse?"
$100 Flood hazard requirements apply if a loan is secured by this. Answer: "What is improved property or an affixed mobile home?" $200
In order for a Reg Z-covered loan to be subject to a right of rescission, this must be the collateral. Tell them the answer to this one must be carefully worded!
Answer: "What is a consumer's principal dwelling?" You should deduct a few points if they merely answer "What is the borrower's principal dwelling?", for example, because the person pledging the dwelling may not be the borrower.
The number of acres the collateral must consist of in order for the loan to be exempt from RESPA.
Answer: "What is 25 or more?"
In order for HMDA to apply on a home purchase loan, the lender must get a security interest in ______________ .
Tell them you're going to be picky about the wording of the answer!
Answer: "What is a dwelling?" If their answer is "What is the home being purchased?", deduct points because the loan does not have to be secured by that particular property, it just needs to be secured by a dwelling.
Two things you should check out before making a loan.
(besides the purpose, the type of borrower, the type of collateral, and the amount)
Answer: "What are the OFAC list and the borrower's identity?"
Operations Compliance Jeopardy Questions
Category: Operations Disclosures/Notices
This disclosure isn't required for savings accounts.
Answer: "What is the funds availability disclosure?"
On a joint account, the privacy disclosure must be given to ___________.
Answer: "What is either joint owner?"
If an individual calls and wants to know rate information, you must quote this.
Answer: "What is the Annual Percentage Yield?"
Under BSA, you can't tell the customer you are filing one of these.
Answer: "What is a Suspicious Activity Report?"
You cannot apply a redeposited check exception hold for a check returned due to ____ or ____.
Answer: "What are l) missing endorsement and 2) postdating?"
The first $100 rule under Reg CC doesn't apply if you use a ____________ exception hold.
Answer: "What is reasonable cause to doubt collectibility?"
If a customer deposits $2,000 in cash and a $9,000 local check on a Monday, this amount must be made available for withdrawal on Tuesday.
Answer: "What is $2,100?"
This law was designed to allow consumers to do comparison shopping for deposit accounts.
Answer: "What is Truth in Savings?"
You must obtain this for each customer seeking to open a deposit account.
Answer: "What is verification of identity?"
Deposits made in a night deposit over the weekend are counted as having been made _____________.
Answer: "What is on the next business day following the deposit?"
Category: Coverage Issues
Number of days you normally initially have to investigate a claim of EFT error.
Answer: "What is ten business days?"
Two operations laws/regs which do not apply to business customers.
Answer: "What are Truth in Savings and GLB privacy?"
CTR requirements apply to deposits, withdrawals, payments, transfers and _______________ of currency.
Answer: "What are exchanges?"
For-profit corporations and partnerships are not eligible for _____________ .
Answer: "What are NOW accounts?"
You can waive the Reg D early withdrawal penalty on a CD upon ______________.
Answer: "What is the death of an owner?"
When a customer attempts to evade the currency transaction reporting requirements, that's called ________________ .
Answer: "What is structuring?"
The original version appeared in the September 2002 edition of the Oklahoma Bankers Association Compliance Informer.
First published on BankersOnline.com 1/27/03
First published on 01/27/2003