1|Page
CFCI Exam 2025 — Certified Financial Crime
Investigator Study Guide, Practice Test Questions,
and Certification Preparation
Prepare for the Certified Financial Crime Investigator (CFCI) Exam 2025 with the most
updated study guide, practice test questions, and certification materials. Learn essential
topics in anti-money laundering (AML), fraud detection, financial compliance, and risk
management to pass your CFCI certification on your first try.
• CFCI exam 2025
• Certified Financial Crime Investigator certification
• CFCI practice test and answers
An outline of the escalation process in response to suspicious activity incidents. This process
should be clearly communicated to all employees, regardless of their role in the company. -
ANSWER-Loan fraud department policies should include #1
Communication and reporting requirements for management, legal, internal audit, human
resources, and each business line. Escalation thresholds should be defined - ANSWER-Loan
fraud department policies should include #2
A definition of the escalation process in response to law enforcement and legal inquiries. The
fraud department should maintain close contact with the institution's legal department and
function as its investigative resource for customer/attorney complaints and law enforcement
inquiries - ANSWER-Loan fraud department policies should include #3
,2|Page
Suspicious activity report (SAR) procedures, if applicable - ANSWER-Loan fraud department
policies should include #4
Secondary marketing requirements for investor notifications, if required. The parameters for
notification and a definition of the process should be determined internally - ANSWER-Loan
fraud department policies should include #5
A process for terminating or suspending third-party relationships. The fraud department should
establish collaborative business relationships with the departments responsible for maintaining
third-party relationships - ANSWER-Loan fraud department policies should include #6
Reporting requirements for outside parties, such as the Mortgage Industry Data Exchange
(MIDEX) database maintained by LexisNexis, credit bureaus, law enforcement agencies,
licensing bureaus, and so on - ANSWER-Loan fraud department policies should include #7
Monitor exception reports. Screen for loans that were approved outside of normal guidelines,
lists of suspect items, or loan document exceptions. Also determine who approved loans with
these irregularities and inquire about the reasons for the errors - ANSWER-To monitor for
suspicious activity in a loan portfolio #6
Monitor early delinquency, early payoff, or investor repurchase and charge-off trends to identify
recurring brokers, originators, underwriters, or other parties. - ANSWER-To monitor for
suspicious activity in a loan portfolio #7
Monitor documents and reports from internal departments, business partners, and other
organizations that could include contract compliance, outstanding final documents, mortgage
insurance premium payments, and quality control exception reports. Make management
responsible for reviewing and approving or rejecting all exceptions - ANSWER-To monitor for
suspicious activity in a loan portfolio #8
,3|Page
Review insurance code changes. Use monthly reports identifying loans with origination dates
within the last six months for which the status of the property was changed from owner-
occupied to investment - ANSWER-To monitor for suspicious activity in a loan portfolio #9
Monitor change-of-address requests. Address changes for loans on properties within six months
of origination can indicate investor versus owner-occupied properties or straw buyer frauds. -
ANSWER-To monitor for suspicious activity in a loan portfolio #10
Track addresses of declined applications for three months to check for new applications that can
point to instances of straw buyers or multiple loans - ANSWER-To monitor for suspicious activity
in a loan portfolio #11
Examine commercial floor plan lines of credit to identify out-of-trust situations - ANSWER-To
monitor for suspicious activity in a loan portfolio #12
Form an asset review committee or problem loan committee that meets monthly to review
problem assets, trends, and problematic relationships. - ANSWER-To monitor for suspicious
activity in a loan portfolio #13
Protocols for responding to hotline reports. Hotline complaints should be investigated and
resolved quickly and thoroughly. The hotline also should be available to customers and the
public to report misconduct. - ANSWER-Loan fraud department policies should include #8
A properly conducted prefunding field examination provides a critical opportunity to uncover
fraud or other unknown significant borrowing base or accounting issues. Not closing a loan is, at
times, the necessary result. - ANSWER-Conducting Prefunding Field Examinations
Enforce a policy prohibiting any loan address from being coded "hold mail." - ANSWER-Specific
Loan Fraud Prevention Checklist #1
, 4|Page
If "hold mail" coding is unavoidable, require all mail directed to the borrower to be directed to
an individual who is independent of the borrower. Then require the independent person to sign
an authorization form for retrieving the mail. Any mail not retrieved within 30 days should be
forwarded directly to the borrower. If the borrower cannot be contacted by mail, chances are
the loan is fictitious - ANSWER-Specific Loan Fraud Prevention Checklist #2
Have your internal audit or loan operations department run periodic computer reports to
screen for multiple loans with no apparent legitimate connection, but with the same mailing
address— usually a PO box. (Possible fraudulent straw buyer schemes.) - ANSWER-Specific Loan
Fraud Prevention Checklist #3
Require certified, nonbank appraiser to conduct appraisals for all loan applications over a
specified amount. (Possible nominee/straw buyer/asset-based loan fraud.) - ANSWER-Specific
Loan Fraud Prevention Checklist #4
Regularly monitor for loans with partial charge-offs that do not appear on the bank's problem
loan list. This may indicate a nominee loan where the bank employee charged off a certain
amount to keep the loan balance below the minimum that would trigger increased scrutiny. -
ANSWER-Specific Loan Fraud Prevention Checklist #5
Establish automated systems that flag loans with addresses that match those of existing loans in
the bank's portfolio. (Possible straw buyer or fictitious loans.) - ANSWER-Specific Loan Fraud
Prevention Checklist #6
Ensure proper segregation of duties with regard to loan disbursements and loan payments. No
single employee should have access to computer systems that manage general ledger activity or
are dedicated to disbursements - ANSWER-Specific Loan Fraud Prevention Checklist #7
Regularly review board minutes and interview senior management to screen for possible
requests or attempts to change appraisers. (May indicate collusion between insider and
CFCI Exam 2025 — Certified Financial Crime
Investigator Study Guide, Practice Test Questions,
and Certification Preparation
Prepare for the Certified Financial Crime Investigator (CFCI) Exam 2025 with the most
updated study guide, practice test questions, and certification materials. Learn essential
topics in anti-money laundering (AML), fraud detection, financial compliance, and risk
management to pass your CFCI certification on your first try.
• CFCI exam 2025
• Certified Financial Crime Investigator certification
• CFCI practice test and answers
An outline of the escalation process in response to suspicious activity incidents. This process
should be clearly communicated to all employees, regardless of their role in the company. -
ANSWER-Loan fraud department policies should include #1
Communication and reporting requirements for management, legal, internal audit, human
resources, and each business line. Escalation thresholds should be defined - ANSWER-Loan
fraud department policies should include #2
A definition of the escalation process in response to law enforcement and legal inquiries. The
fraud department should maintain close contact with the institution's legal department and
function as its investigative resource for customer/attorney complaints and law enforcement
inquiries - ANSWER-Loan fraud department policies should include #3
,2|Page
Suspicious activity report (SAR) procedures, if applicable - ANSWER-Loan fraud department
policies should include #4
Secondary marketing requirements for investor notifications, if required. The parameters for
notification and a definition of the process should be determined internally - ANSWER-Loan
fraud department policies should include #5
A process for terminating or suspending third-party relationships. The fraud department should
establish collaborative business relationships with the departments responsible for maintaining
third-party relationships - ANSWER-Loan fraud department policies should include #6
Reporting requirements for outside parties, such as the Mortgage Industry Data Exchange
(MIDEX) database maintained by LexisNexis, credit bureaus, law enforcement agencies,
licensing bureaus, and so on - ANSWER-Loan fraud department policies should include #7
Monitor exception reports. Screen for loans that were approved outside of normal guidelines,
lists of suspect items, or loan document exceptions. Also determine who approved loans with
these irregularities and inquire about the reasons for the errors - ANSWER-To monitor for
suspicious activity in a loan portfolio #6
Monitor early delinquency, early payoff, or investor repurchase and charge-off trends to identify
recurring brokers, originators, underwriters, or other parties. - ANSWER-To monitor for
suspicious activity in a loan portfolio #7
Monitor documents and reports from internal departments, business partners, and other
organizations that could include contract compliance, outstanding final documents, mortgage
insurance premium payments, and quality control exception reports. Make management
responsible for reviewing and approving or rejecting all exceptions - ANSWER-To monitor for
suspicious activity in a loan portfolio #8
,3|Page
Review insurance code changes. Use monthly reports identifying loans with origination dates
within the last six months for which the status of the property was changed from owner-
occupied to investment - ANSWER-To monitor for suspicious activity in a loan portfolio #9
Monitor change-of-address requests. Address changes for loans on properties within six months
of origination can indicate investor versus owner-occupied properties or straw buyer frauds. -
ANSWER-To monitor for suspicious activity in a loan portfolio #10
Track addresses of declined applications for three months to check for new applications that can
point to instances of straw buyers or multiple loans - ANSWER-To monitor for suspicious activity
in a loan portfolio #11
Examine commercial floor plan lines of credit to identify out-of-trust situations - ANSWER-To
monitor for suspicious activity in a loan portfolio #12
Form an asset review committee or problem loan committee that meets monthly to review
problem assets, trends, and problematic relationships. - ANSWER-To monitor for suspicious
activity in a loan portfolio #13
Protocols for responding to hotline reports. Hotline complaints should be investigated and
resolved quickly and thoroughly. The hotline also should be available to customers and the
public to report misconduct. - ANSWER-Loan fraud department policies should include #8
A properly conducted prefunding field examination provides a critical opportunity to uncover
fraud or other unknown significant borrowing base or accounting issues. Not closing a loan is, at
times, the necessary result. - ANSWER-Conducting Prefunding Field Examinations
Enforce a policy prohibiting any loan address from being coded "hold mail." - ANSWER-Specific
Loan Fraud Prevention Checklist #1
, 4|Page
If "hold mail" coding is unavoidable, require all mail directed to the borrower to be directed to
an individual who is independent of the borrower. Then require the independent person to sign
an authorization form for retrieving the mail. Any mail not retrieved within 30 days should be
forwarded directly to the borrower. If the borrower cannot be contacted by mail, chances are
the loan is fictitious - ANSWER-Specific Loan Fraud Prevention Checklist #2
Have your internal audit or loan operations department run periodic computer reports to
screen for multiple loans with no apparent legitimate connection, but with the same mailing
address— usually a PO box. (Possible fraudulent straw buyer schemes.) - ANSWER-Specific Loan
Fraud Prevention Checklist #3
Require certified, nonbank appraiser to conduct appraisals for all loan applications over a
specified amount. (Possible nominee/straw buyer/asset-based loan fraud.) - ANSWER-Specific
Loan Fraud Prevention Checklist #4
Regularly monitor for loans with partial charge-offs that do not appear on the bank's problem
loan list. This may indicate a nominee loan where the bank employee charged off a certain
amount to keep the loan balance below the minimum that would trigger increased scrutiny. -
ANSWER-Specific Loan Fraud Prevention Checklist #5
Establish automated systems that flag loans with addresses that match those of existing loans in
the bank's portfolio. (Possible straw buyer or fictitious loans.) - ANSWER-Specific Loan Fraud
Prevention Checklist #6
Ensure proper segregation of duties with regard to loan disbursements and loan payments. No
single employee should have access to computer systems that manage general ledger activity or
are dedicated to disbursements - ANSWER-Specific Loan Fraud Prevention Checklist #7
Regularly review board minutes and interview senior management to screen for possible
requests or attempts to change appraisers. (May indicate collusion between insider and
