COMPLIANCE JEOPARDY

Policy Basics

100

This is the first place a team member should go when they need to confirm the official requirement for a particular process.

What is the applicable OneMain policy or procedure?

200

A team member creates a check in the B81 Checks screen. Before the check can be printed, this approval must be completed by someone other than the team member who created it.

What is secondary approval from a non-subordinate team member?

300

During a collection call, you learn that the customer is in a medical facility and expects to remain there for 45 days. What must you do regarding the customer’s phone number, and what type of call is permitted during the customer’s stay?

What is place the applicable number(s) in DNC status and allow only one non-collection call per month to confirm whether the customer is still in the facility? 

400

When setting up recurring payments using Telephone Authorization, what must the team member do before selecting Set Schedule?

The team member must:

• Ensure the email address belongs to the person making the payment.
• Select Telephone Recording as the authorization method.
• Use only an email address—a mobile phone number cannot be used.
• Read the Payment Authorization script exactly as displayed to the customer on the Payment Authorization line at 888-303-7334.
• After the customer accepts the authorization, select Set Schedule.

500

A non-obligor is present at a loan closing. What steps must the team member complete before allowing the non-obligor to sign the required documentation?

The team member must:

• Verify the non-obligor’s identity and retain copies of the verification documents in ELF.
• Provide the non-obligor with only a blank copy of the Loan Agreement.
• Obtain the non-obligor’s signature on the Non-Obligor Signature Section Form
• Retain the signed form in the appropriate location:
  • Wet signature closing: Customer’s loan file.
  • eSignature closing: Scan the signed form into ELF.

Procedures

100

If One-Time Passcode (OTP) fails for either applicant on a joint application, what must the branch do with the loan closing method?

What is change the loan closing method to In-Branch?

200

A customer confirms that the income reported by the third-party verifier is inaccurate. The team member cannot use that income to qualify the customer. What must the team member do next?

What is exclude or delete the third-party verified income, request income documentation, and manually verify the income?

300

A customer’s Deferment Agreement was completed on the 5th. A post-dated debit card payment scheduled for the 15th fails, canceling the deferment. The customer successfully replaces the payment on the 16th, within the same month. When reapproving the deferment, what authorization method must be selected?

Even though the original agreement was obtained verbally, a systemic reapproval requires “Written” to be selected to avoid a compliance reporting discrepancy.

400

A customer’s temporary modification expired, and 45 days later another temporary modification was activated. The customer now wants a renewal after making 8 full contractual payments. What additional approval is required before the renewal can proceed?

What is CU exception approval?

Why: The second modification occurred within 60 days of the first one expiring, making it a back-to-back temporary modification. With 6–11 full contractual payments, CU exception approval is required.

500

A borrower has an OFAC Alert on their CBR, and the alert is received on a Saturday. What should the team member do, and when can the alert be cleared?

The team member should:

• Do not inform the borrower about the OFAC Alert.
• Complete and submit the OFAC Screening Form, selecting “Individual.”
• Because the alert was received outside business hours, it must be cleared on the next business day (Monday).
• Once the OFAC Alert Team responds, follow their instructions.
• The OFAC flag must be cleared before extending credit.

Compliance

100

When obtaining a verbal deferment authorization, what two actions must the team member complete to properly document the authorization?

What are reading the script on the recorded authorization line and notating the account that the authorization/Verification line was called?

DEF AUTH LINE: 833-390-2001
*not the same as the ACH line*

200

A customer makes a payment intended to satisfy a deferment, but the BA Request and Deferment Agreement were not completed before the payment posted. The team member wants to submit a CRA to have the payment applied to a manual deferment. What should they do?

What is not use the payment for a deferment and do not submit a CRA request?

300

In which two instances can stated income be used

What is an SDA and modification when Risk notes state no income documents are required?

400

During a collection call a Borrower's Assistance option was agreed upon that defers unpaid interest to the end of the loan but does not extend the contractual maturity date, but can create payments due past the maturity. Which BA tool was selected?

What is re-age?

500

A CBR shows an Initial Fraud Alert, but the phone number listed in the alert is disconnected. The applicant confirms they placed the alert and correctly verifies the phone number that was listed. What must the team member do next before proceeding with the application?

The team member must:

• Complete the additional identity verification process.
• Have the applicant complete OTP verification.
• Obtain a Social Security Card and Proof of Address (such as a utility bill).
• Document in CLASS how the fraud alert was cleared, including that the applicant verified the consumer statement and the phone number from the alert.
• Do not tell the applicant that a fraud alert appeared on the CBR

Customer Service

100

A customer’s income is successfully verified through a third-party source. The customer verbally confirms that the verified income amount is accurate and that the income is sufficient to qualify for the requested loan amount. What should the team member do?

What is retain the third-party verified income and not request additional income documents?

200

A customer requests a refund for a non-cash payment that was posted 10 days ago. What documentation and approvals are required before processing the refund?

The team member must:

• Obtain a bank statement, screenshot, or electronic image showing the payment cleared.
• Ensure it shows the beginning and ending balances, transaction amount, date, and that the transaction is complete (not pending).
• Scan the documentation into ELF.
• Obtain BM or above approval, with the approval noted on the account including the payment date and refund amount.
• DM approval is only required if there is a documentation exception

300

Third party documentation was used to verify employment. What must be included in should the team member enter to verify employment when applicable?

What is enter employer phone number?

400

A customer has $75 in accrued late fees that are due but have not yet been collected. The team member is working with the customer on their past-due account. Who must approve the waiver, and what must be documented?

Who is the District Manager, and the approval must be fully documented in the account notes?

TM: $25
BM: $50
DM: $100
RD: $100+

500

A customer submits a written request for a due date change, but the team member cannot contact the customer because the account has a DNC restriction. What must the team member do before processing the due date change?

The team member must:

• Select Yes on the script pop-up.
• Document in the account notes that the Company cannot call the customer, why the customer cannot be called, and that a written request was received.
• Scan the written request into ELF.
• Document the customer's due date change request in the account notes.
• Process the due date change in CLASS/B66 once all required approvals and requirements are met.
• Scan any applicable wet-signature or email documentation into ELF.

What would you do?

100

After approval, you verify the vehicle’s actual odometer mileage. If the actual mileage is greater than a 5,000-mile variance from the mileage entered on the application, this action is required.

What is update the odometer and vehicle value & reapprove quote if necessary 

200

When an applicant or co-applicant has a tradeline reporting as an Authorized User (AU) account, what amount should be entered in the Monthly Payment field?

What is $1.00?

*Include full payment if customer is responsible for payment- always notate app 

300

A customer wants to renew their loan. Within the last 20 calendar days, they made two non-guaranteed payments totaling more than two contractual payments. The most recent non-guaranteed payment was made 10 days ago, and the customer cannot provide documentation showing the funds have cleared. What must happen before the renewal can be booked?

What is wait until 20 calendar days have passed from the date of the most recent non-guaranteed payment?

400

A customer responds to an outreach text and asks for their loan rate, account number, and date of birth so the team member can confirm their identity. According to policy, what should the team member do?

What is do not request or disclose PII or discuss application, approval, or loan details by text

500

During an in-branch kiosk eSignature closing, the borrower refuses to sign the Electronic Loan Closing Borrower Attestation because the team member controlled the mouse and clicked on the screen during the eSignature process. What must the team member do?

The loan must be voided and rebooked because the borrower must personally perform all actions required to electronically sign the loan documents. The attestation must also be properly signed and scanned into ELF for a valid kiosk eSignature closing.