NMLS Recordkeeping and Reporting 2 — Questions and Answers
Question 1: Under the Bank Secrecy Act (BSA), mortgage companies must file a Suspicious Activity Report (SAR) within how many days of detecting a suspicious transaction?
- 15 days
- 30 days (Correct answer)
- 45 days
- 60 days
Correct answer: 30 days
SARs must be filed within 30 days of initial detection of suspicious activity, or up to 60 days if no suspect is identified initially.
Question 2: Which federal agency is primarily responsible for enforcing BSA compliance for non-depository mortgage lenders?
- Federal Reserve
- OCC
- FinCEN (Correct answer)
- FDIC
Correct answer: FinCEN
FinCEN (Financial Crimes Enforcement Network) is the primary BSA regulator for non-bank mortgage lenders and brokers.
Question 3: A mortgage company's HMDA Loan Application Register (LAR) must be submitted to regulators by which date each year?
- January 1
- March 1 (Correct answer)
- April 15
- June 30
Correct answer: March 1
HMDA LAR data must be submitted to the CFPB by March 1 of the year following data collection.
Question 4: For HMDA purposes, which loan action type must be reported when an applicant withdraws their application before a credit decision is made?
- Application denied
- Application withdrawn (Correct answer)
- File closed for incompleteness
- Loan originated
Correct answer: Application withdrawn
When a borrower voluntarily withdraws their application prior to a credit decision, it is reported as 'Application withdrawn' on the LAR.
Question 5: Under RESPA, how long must a mortgage servicer retain escrow account records after a loan is paid off or transferred?
- 1 year
- 2 years
- 3 years (Correct answer)
- 5 years
Correct answer: 3 years
RESPA requires servicers to retain escrow account records for a minimum of 3 years after the loan is paid in full or transferred.
Question 6: A Currency Transaction Report (CTR) is required when a customer conducts cash transactions exceeding what threshold in a single business day?
- $5,000
- $7,500
- $10,000 (Correct answer)
- $25,000
Correct answer: $10,000
Financial institutions must file a CTR for any cash transaction or series of related transactions exceeding $10,000 in one business day.
Question 7: Which NMLS record must be updated within 30 days of a material change such as a change in the licensee's legal name?
- MU4 form (Correct answer)
- MU1 form
- MU2 form
- MU3 form
Correct answer: MU4 form
The MU4 is the individual mortgage loan originator form and must be amended within 30 days of any material change, including a legal name change.
NMLS Recordkeeping and Reporting 2
Under the Bank Secrecy Act (BSA), mortgage companies must file a Suspicious Activity Report (SAR) within how many days of detecting a suspicious transaction?