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Ethics & Fraudmedium18% of exam

A branch manager asks about a loan file because an outside party asks for borrower bank statements without a permissible basis. What should happen?

Correct Answer

A) Follow privacy limits before sharing nonpublic personal information

Lines 273-277; 12 CFR Part 1016 summary and Subparts A-B. Borrower nonpublic personal information is subject to privacy notices and sharing limits. Therefore, the correct response is "Follow privacy limits before sharing nonpublic personal information".

Answer Options
A
Follow privacy limits before sharing nonpublic personal information
B
Treat the compliance requirement as optional because closing is near.
C
Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.
D
Ignore the issue if the borrower orally agrees to continue.

Why This Is the Correct Answer

The correct response is "Follow privacy limits before sharing nonpublic personal information". Borrower nonpublic personal information is subject to privacy notices and sharing limits.

Why the Other Options Are Wrong

Option B: Treat the compliance requirement as optional because closing is near.

Treat the compliance requirement as optional because closing is near. is not correct because the governing rule requires the compliant answer shown in the explanation.

Option C: Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.

Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue. is not correct because the governing rule requires the compliant answer shown in the explanation.

Option D: Ignore the issue if the borrower orally agrees to continue.

Ignore the issue if the borrower orally agrees to continue. is not correct because the governing rule requires the compliant answer shown in the explanation.

Memory Technique

Outside party plus borrower data means pause and verify authority.

Exam Tip

Outside party plus borrower data means pause and verify authority.

Common Mistakes to Avoid

  • -Closing a loan does not remove privacy duties for borrower information.
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