Specialty Certification

Certified Consumer Protection Examiner

Objectives of the Compliance Examiner Certification Program:

  • To achieve recognition of the specialized knowledge, skills, and abilities required for the examination of consumer finance and debt collection companies of all sizes and complexities to determine their compliance with state and federal consumer protection laws and regulations applicable to regulated entities.
  • To promote continuing education in the consumer compliance/protection supervision area.
  • To emphasize the need for professionalism and continuing advancement of consumer compliance/protection examination professionals given the specialized skills and knowledge necessary to adequately supervise this area.
  • To enhance and maintain the quality of job performance and skill level of these specialized examiners.

Candidates for the Certified Consumer Protection Examiner (CCPE) designation must provide evidence of the following:

  • Completion of 2 years’ experience of on-the-job service and training as an assisting examiner and examiner in charge to determine compliance with applicable state and federal consumer protection laws and regulations in any one of the businesses that provide financial services to consumers, such as consumer finance companies, or debt collection companies, as follows:
    • Participation in 10 exams utilizing established examination procedures for both limited and full-scope examinations with minimal supervision. If necessary, this requirement may be adjusted in accordance with the size of your state and the number of exams being conducted. Supporting details must be provided in the application.
  • Satisfactory completion of core consumer protection classroom training, as follows, or an equivalent:
  • Attestation of successful job performance and mastery of appropriate job-related skills by the candidate’s immediate supervisor or other senior employee who is familiar with the applicant’s experience, performance, and skills and abilities. The supervisor or other qualified individual must attest that the applicant meets or exceeds expectations with regard to all competencies listed below and the examination requirement.

TECHNICAL

  • Provides effective leadership and organization to the examination process: Demonstrates effective skills to plan, organize and delegate examination/inspection functions including analyzing data and forming logical conclusions.

  • Effectively adheres to examination policies and procedures.

  • Actively participates in training of coworkers and colleagues as appropriate and necessary.

  • Supervises, organizes, and effectively documents workpapers according to prescribed procedures

  • Familiar with Microsoft office suite

  • Ability to conduct data analysis, utilizing pivot tables as applicable.

CONCEPTUAL – Provides effective and accurate evaluation of the operational and financial activities of non-depository institutions:
 

  • Provides effective and accurate evaluation of the overall activities of non-bank financial institutions relating consumer finance and debt collection business activities.
  • Effectively demonstrates knowledge of Consumer Finance and Debt Collection policies, procedures, laws, rules and regulations – both state and federal

  • Effectively follows established and accepted examination procedures to collect and analyze data

  • Preparation of written comments is factually and technically correct

  • Workpapers support report of examination with detailed information and provide a clear audit trail

  • Effectively reviews reports of examination for accuracy, content, conclusions, and proper grammar

  • Aware of the various types of Consumer Finance and Debt Collection companies and the risks involved with each

  • Knowledge of state-specific reports

  • Knowledge of financials including the balance sheet, income statement;

  • Knowledge of Federal Financial Institutions Examination Council (FFIEC) rating system;

LEGAL/COMPLIANCE – Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations:

  •  Familiar with state regulations and the industry, kinds of industries regulated (state and federal), and Uniform Consumer Credit Code.

  • A need to have knowledge of the following federal laws and regulations as applicable, which may include but not are not limited to:

    • Office of Foreign Assets Control (OFAC) regulations

    • 12 USC Ch. 53 Dodd-Frank Act (UDAAP)

    • 15 USC Ch. 96 E-Sign Act

    • 15 USC Ch. 41 Fair Lending

    • 10 USC § 987 Military Lending Act

    • 50 USC Ch. 50 Servicemembers' Civil Relief Act

    • 12 CFR 1002- Regulation B (Equal Credit Opportunity Act)

    • 12 CFR 1005- Regulation E (Electronic Funds Transfer Act)

    • 12 CFR 1006- Regulation F (Fair Debt Collection Practices Act)

    • 12 CFR 1016- Regulation P (Privacy of Consumer Financial Information)

    • 12 CFR 1022- Regulation V (Fair Credit Reporting Act)

    • 12 CFR 1026- Regulation Z (Truth in Lending)

    • 12 CFR 1041- Payday, Vehicle Title, and Certain High-Cost Installment Loans (Payday Lending Rule)

  • Safeguards consumer information - Title 16, CFR, Part 314 Standards for Safeguarding Customer Information, implements sections 501 and 505(b)(2) of the Gramm-Leach-Bliley Act

HUMAN RELATIONS – Provides effective oral and written communications:
 

  • Effectively communicates assignments to assisting examination personnel.

  • Effectively communicates with non-bank financial institution/licensee management/personnel to obtain information.

  • Effectively communicates with other regulatory agencies regarding finding/issues related to an examination.

  • Presents logical supporting documentation in response to any management concerns and moderates own conclusions if presented with sufficiently supported data by management.

  • All meetings are performed in an organized and professional manner.

  • Recommendations and ratings demonstrate a thorough and successful understanding of regulations, statutes, and directives as applicable to the entity under examination/inspection.

  • Needs to demonstrate effective organizational skills when it comes to assignments and workpapers, effective time management.

RECERTIFICATION

Every three years, CCPE certified examiners will be required to provide evidence of the successful completion of a minimum of 40 continuing education hours (CEHs); at least seven CEHs must be completed each year. Examples of qualifying programs and activities are listed below. Other programs and activities submitted will be considered on a case-by-case basis. Continuing education should be selected with the goal of maintaining, improving, or expanding the examiner’s knowledge, skills, and abilities.

  • CSBS Leadership Effectiveness and Development (LEAD)
  • FDIC Compliance Training Program – Community Reinvestment Act (CRA)
  • FFIEC Consumer Compliance Specialists Conference
  • FFIEC Fundamentals of Fraud Workshop
  • FFIEC Fraud Investigation Techniques for Examiners
  • FFIEC Fraud Investigations Symposium
  • FFIEC Unfair, Deceptive, or Abusive Acts or Practices Workshop
  • FFIEC Financial Crimes Seminar
  • National Association of Consumer Credit Administrators (NACCA) Consumer Services and Examiners’ School
  • FFIEC Information Technology (IT) Conference 
  • FFIEC Information Technology (IT) Symposium
  • FFIEC Payment Systems Risk Conference
  • FFIEC Supervisory Updates & Emerging Issues for Community Financial Institutions
  • Wolters Kluwer CRA Wiz and Fair Lending Wiz Training
  • Relevant Trainings from:
    • American Bankers’ Association (ABA) Webinars & Courses
    • OnCourse Learning
    • NContracts Webinars
    • LRN

    • State Bankers Associations

    • State attorney general offices or National Association of Attorneys General

    • Office of the Comptroller of the Currency (OCC) Digital Media Library
    • National Credit Union Administration (NCUA)
    • Association of Certified Anti-Money Laundering Specialists (ACAMS)
    • Risk Management Association (RMA)
    • Association of Certified Fraud Examiners (ACFE)

    • National Association of Consumer Advocates (NACA)

  • Applicable portions of Annual Conferences or other seminars, not utilized for minimum certification requirements, of:

    • Conference of State Bank Supervisors (CSBS)

    • Nationwide Multistate Licensing System & Registry (NMLS) 

    • National Association of Consumer Credit Administrators (NACCA)

    • Federal Financial Institutions Examination Council (FFIEC)

    • North American Collection Agency Regulatory Association (NACARA)

  • Relevant courses in CSBS FLEX such as:

    • The ACH Network

    • Financial Accounting: GAAP, Liabilities and Stockholder's Equity

    • Financial Accounting: GAAP and Asset Recognition

    • Frontline: ACH, Wire, and Remittance Transfers

    • Financial Accounting: The Basic Financial Statements

    • Using NMLS for Agency Examiners

    • E-Sign Act: Benefits and Risks

    • IT Examiner School

    • Baseline Nonbank Cybersecurity Exam Program Virtual Discussion Series

    • Third-Party Cyber Risk

    • Operational Risk: Information Technology (4 parts)

    • Cybersecurity: Computer Security Basics

    • Internet Security Essentials for Financial Institutions