Certified Regulatory Compliance Manager (CRCM) — Question 191

The OCC has determined that a national bank may not assume that, simply because a consumer's PIN or ATM card was used in a transaction, that transaction is authorized. Banks are required to take reasonable steps to determine whether the transaction was authorized. Such steps might include the bank's review of:

Answer options

• A. Documentation or written, signed statements provided by the consumer
• B. Historical information on the customer's pattern of use (such as time, location, types of transactions, and so on)
• C. Problems reported by regular customers regarding the access device or ATM
• D. Legal reports

Correct answer: A, B

Explanation

Options A and B are correct because they represent reasonable steps banks can take to verify the authorization of a transaction. Option C, while relevant, does not directly provide evidence of authorization, and option D is not applicable as legal reports do not pertain to transaction verification.