Quoted from JBAS-1600:

"I see that we do not handle the propagation of CreateExceptions thrown from stateless session ejbCreate callbacks correctly due to the delay of the instance creation until a remote method invocation. The problem this causes is that a CreateException is an application exception that when thrown during a business method invocation results in an UndeclaredThrowableException due to an undeclared checked exception being thrown from the reflected method invocation."

This also aplies to 3.2.x