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A depository institution has a branch with six originators. It gives them a manual and annual training but has no procedure for monitoring compliance with the compensation, steering, qualification, and identification rules. Under Regulation Z section 1026.36(j), what is missing?

Correct Answer

B) Written procedures reasonably designed to monitor compliance, appropriate to its mortgage activities

B. Written compliance-monitoring procedures are missing. The specified rule requires policies and procedures both to ensure compliance and to monitor it. Their design must fit the institution’s mortgage activities; distributing a manual and training does not establish the missing monitoring process. Scope and exceptions: Section 1026.36(j) addresses depository institutions and compliance with paragraphs (d)–(g). Do not infer that every institution needs identical staffing, or that this provision exhausts other entities’ obligations. Source: Section 1026.36(j)(1)–(2) — https://www.consumerfinance.gov/rules-policy/regulations/1026/36/

Answer Options
A
A second training day, which alone satisfies the monitoring requirement
B
Written procedures reasonably designed to monitor compliance, appropriate to its mortgage activities
C
A dedicated on-site compliance officer at every branch, regardless of size
D
Employee signatures on the manual, which replace ongoing monitoring

Why This Is the Correct Answer

B. Written compliance-monitoring procedures are missing. The specified rule requires policies and procedures both to ensure compliance and to monitor it. Their design must fit the institution’s mortgage activities; distributing a manual and training does not establish the missing monitoring process. Scope and exceptions: Section 1026.36(j) addresses depository institutions and compliance with paragraphs (d)–(g). Do not infer that every institution needs identical staffing, or that this provision exhausts other entities’ obligations.

Why the Other Options Are Wrong

Option A: A second training day, which alone satisfies the monitoring requirement

Another training session alone does not supply monitoring.

Option C: A dedicated on-site compliance officer at every branch, regardless of size

The provision does not mandate one on-site officer at every branch.

Option D: Employee signatures on the manual, which replace ongoing monitoring

Employee acknowledgements do not replace monitoring.

Exam Tip

Training communicates rules; monitoring tests whether practices follow them.

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