CMCP LATEST 2026 TEST PAPER QUESTIONS AND
SOLUTIONS GRADED A+
✔✔What factors should institutions consider when implementing monitoring and/or audit
programs? - ✔✔Size, risk profile, and complexity of services offered.
✔✔Are monitoring and/or audit programs necessary for all lenders? - ✔✔Not
necessarily, depends on size, complexity, and risk profile.
✔✔What will examiners evaluate if an institution does not have both monitoring and
audit functions? - ✔✔Coverage commensurate with institution's size, complexity, and
risk profile.
✔✔Who is responsible for monitoring in the business units? - ✔✔First line of defense
(business units).
✔✔What is the objective of monitoring? - ✔✔To promptly identify and correct HMDA
issues.
✔✔How does monitoring differ from audit? - ✔✔More frequent, less formal, and may be
carried out by business units or compliance department.
✔✔Does monitoring need to be independent from business units or compliance
department? - ✔✔No, it does not need to be independent.
✔✔What should a structured HMDA monitoring program include? - ✔✔Frequency and
scope of testing, process to escalate and correct weaknesses.
✔✔What is the role of processors in the pre-closing review process? - ✔✔Checking
HMDA data for each loan using a checklist and source document chart.
✔✔What happens with the results of the pre-closing review process? - ✔✔Results are
summarized, reported, and corrected.
✔✔What is the purpose of monitoring by the Compliance Department? - ✔✔To select
and test loans for compliance, including HMDA compliance.
✔✔What is the purpose of the audit function? - ✔✔To provide an independent
evaluation of HMDA compliance.
✔✔Who carries out the audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
,✔✔What is the scope and frequency of audits? - ✔✔Generally completed annually,
based on the degree of risk.
✔✔Who can perform the audit function? - ✔✔Internal audit department or an outside
contracted party.
✔✔What does an HMDA audit provide the board with? - ✔✔An evaluation and
determination regarding any deficiencies in HMDA compliance.
✔✔What does the audit department assess during an HMDA audit? - ✔✔The HMDA
CMS and a sample of 50 items on the HMDA Loan Application Register for compliance.
✔✔What are the best practices for monitoring and/or audit? - ✔✔Ongoing monitoring,
less frequent audit, sufficient transactional testing, tailored programs.
✔✔What is the role of the Compliance Department in monitoring? - ✔✔To select and
test loans for compliance, including HMDA compliance.
✔✔What is the role of the Audit function? - ✔✔To provide an independent evaluation of
HMDA compliance.
✔✔Who carries out the Audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
✔✔What is the scope and frequency of Audits? - ✔✔Generally completed annually,
based on the degree of risk.
✔✔Who can perform the Audit function? - ✔✔Internal audit department or an outside
contracted party.
✔✔What does an HMDA Audit provide the board with? - ✔✔An evaluation and
determination regarding any deficiencies in HMDA compliance.
✔✔What does the Audit department assess during an HMDA Audit? - ✔✔The HMDA
CMS and a sample of 50 items on the HMDA Loan Application Register for compliance.
✔✔What are the best practices for monitoring and/or audit? - ✔✔Ongoing monitoring,
less frequent audit, sufficient transactional testing, tailored programs.
✔✔What is the purpose of monitoring by the Compliance Department? - ✔✔To select
and test loans for compliance, including HMDA compliance.
✔✔What is the purpose of the audit function? - ✔✔To provide an independent
evaluation of HMDA compliance.
, ✔✔Who carries out the audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
✔✔What is the role of business unit personnel in HMDA compliance? - ✔✔Monitor
compliance, ensure data accuracy, conduct sample testing.
✔✔What is the role of compliance personnel in HMDA compliance? - ✔✔Perform
ongoing monitoring, review data for outliers, analyze red flags.
✔✔What should compliance personnel ensure in the HMDA process? - ✔✔Decision,
pricing, and processing time reviews.
✔✔What is the role of auditors in HMDA compliance? - ✔✔Perform audits, evaluate
HMDA CMS and data integrity.
✔✔Who should auditors report to in HMDA compliance? - ✔✔Board, independent of
business unit or compliance management.
✔✔What is the role of the board and management in HMDA compliance? - ✔✔Provide
oversight, implement necessary actions.
✔✔What should an effective CMS ensure? - ✔✔Responsiveness and responsibility in
handling consumer complaints and inquiries.
✔✔Why is it important to determine if complaints impact HMDA activity? - ✔✔To take
appropriate action if necessary.
✔✔How should intelligence gathered from consumer contacts be treated? -
✔✔Organized, retained, and considered as part of the institution's CMS.
✔✔What effort should the institution make towards resolving consumer complaints? -
✔✔Deliberate, good faith effort.
✔✔What should management do with consumer complaints? - ✔✔Monitor them to
identify risks and take corrective action.
✔✔When may consumer complaints require retrospective corrective action? - ✔✔When
appropriate to remedy the effects of the institution's actions.
✔✔How does the CFPB use consumer complaints? - ✔✔To determine which
institutions to examine or take enforcement actions against.
SOLUTIONS GRADED A+
✔✔What factors should institutions consider when implementing monitoring and/or audit
programs? - ✔✔Size, risk profile, and complexity of services offered.
✔✔Are monitoring and/or audit programs necessary for all lenders? - ✔✔Not
necessarily, depends on size, complexity, and risk profile.
✔✔What will examiners evaluate if an institution does not have both monitoring and
audit functions? - ✔✔Coverage commensurate with institution's size, complexity, and
risk profile.
✔✔Who is responsible for monitoring in the business units? - ✔✔First line of defense
(business units).
✔✔What is the objective of monitoring? - ✔✔To promptly identify and correct HMDA
issues.
✔✔How does monitoring differ from audit? - ✔✔More frequent, less formal, and may be
carried out by business units or compliance department.
✔✔Does monitoring need to be independent from business units or compliance
department? - ✔✔No, it does not need to be independent.
✔✔What should a structured HMDA monitoring program include? - ✔✔Frequency and
scope of testing, process to escalate and correct weaknesses.
✔✔What is the role of processors in the pre-closing review process? - ✔✔Checking
HMDA data for each loan using a checklist and source document chart.
✔✔What happens with the results of the pre-closing review process? - ✔✔Results are
summarized, reported, and corrected.
✔✔What is the purpose of monitoring by the Compliance Department? - ✔✔To select
and test loans for compliance, including HMDA compliance.
✔✔What is the purpose of the audit function? - ✔✔To provide an independent
evaluation of HMDA compliance.
✔✔Who carries out the audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
,✔✔What is the scope and frequency of audits? - ✔✔Generally completed annually,
based on the degree of risk.
✔✔Who can perform the audit function? - ✔✔Internal audit department or an outside
contracted party.
✔✔What does an HMDA audit provide the board with? - ✔✔An evaluation and
determination regarding any deficiencies in HMDA compliance.
✔✔What does the audit department assess during an HMDA audit? - ✔✔The HMDA
CMS and a sample of 50 items on the HMDA Loan Application Register for compliance.
✔✔What are the best practices for monitoring and/or audit? - ✔✔Ongoing monitoring,
less frequent audit, sufficient transactional testing, tailored programs.
✔✔What is the role of the Compliance Department in monitoring? - ✔✔To select and
test loans for compliance, including HMDA compliance.
✔✔What is the role of the Audit function? - ✔✔To provide an independent evaluation of
HMDA compliance.
✔✔Who carries out the Audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
✔✔What is the scope and frequency of Audits? - ✔✔Generally completed annually,
based on the degree of risk.
✔✔Who can perform the Audit function? - ✔✔Internal audit department or an outside
contracted party.
✔✔What does an HMDA Audit provide the board with? - ✔✔An evaluation and
determination regarding any deficiencies in HMDA compliance.
✔✔What does the Audit department assess during an HMDA Audit? - ✔✔The HMDA
CMS and a sample of 50 items on the HMDA Loan Application Register for compliance.
✔✔What are the best practices for monitoring and/or audit? - ✔✔Ongoing monitoring,
less frequent audit, sufficient transactional testing, tailored programs.
✔✔What is the purpose of monitoring by the Compliance Department? - ✔✔To select
and test loans for compliance, including HMDA compliance.
✔✔What is the purpose of the audit function? - ✔✔To provide an independent
evaluation of HMDA compliance.
, ✔✔Who carries out the audit function? - ✔✔Personnel who are independent of the
HMDA process and do not report to the business line or compliance department.
✔✔What is the role of business unit personnel in HMDA compliance? - ✔✔Monitor
compliance, ensure data accuracy, conduct sample testing.
✔✔What is the role of compliance personnel in HMDA compliance? - ✔✔Perform
ongoing monitoring, review data for outliers, analyze red flags.
✔✔What should compliance personnel ensure in the HMDA process? - ✔✔Decision,
pricing, and processing time reviews.
✔✔What is the role of auditors in HMDA compliance? - ✔✔Perform audits, evaluate
HMDA CMS and data integrity.
✔✔Who should auditors report to in HMDA compliance? - ✔✔Board, independent of
business unit or compliance management.
✔✔What is the role of the board and management in HMDA compliance? - ✔✔Provide
oversight, implement necessary actions.
✔✔What should an effective CMS ensure? - ✔✔Responsiveness and responsibility in
handling consumer complaints and inquiries.
✔✔Why is it important to determine if complaints impact HMDA activity? - ✔✔To take
appropriate action if necessary.
✔✔How should intelligence gathered from consumer contacts be treated? -
✔✔Organized, retained, and considered as part of the institution's CMS.
✔✔What effort should the institution make towards resolving consumer complaints? -
✔✔Deliberate, good faith effort.
✔✔What should management do with consumer complaints? - ✔✔Monitor them to
identify risks and take corrective action.
✔✔When may consumer complaints require retrospective corrective action? - ✔✔When
appropriate to remedy the effects of the institution's actions.
✔✔How does the CFPB use consumer complaints? - ✔✔To determine which
institutions to examine or take enforcement actions against.
