Specialty Certification

Objectives of the CMBE Certification Program:

• To achieve recognition of the skill level required for the examination and review for compliance with state and federal laws and regulations applicable to regulated licensees. Money Service Businesses include money transmitters; currency dealers/exchangers; check cashers; and issuers, sellers or redeemers of traveler’s checks, money orders or stored value products.
• To promote continuing education in the Money Service Business area of the regulation.
• To emphasize the need for professionalism and continuing advancement of Money Service Business 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 Money Service Business Specialists.

Candidates for CMBE designation must provide evidence of all of the following:

• Completion of a minimum of twelve (12) months' experience of on-the-job examination of money service businesses including on and off-site reviews of operational processes, review for compliance with state and federal consumer compliance regulations related to non-bank financial institution/licensees, and review and analysis of compliance with Bank Secrecy Act and Anti-Money Laundering regulations as it relates to MSBs. 
• Participation in at least 4 examinations utilizing established MTRA examination procedures in the last year (including desk reviews). Ability to independently participate on a full-scope exam with minimal supervision, including being able to complete the “core” areas of the MT work program.
• Satisfactory completion of the following course offerings or their equivalent:
  • CSBS Day One MSB Examiner Course (online) and
  • MTRA Operations School
• Attestation of successful job performance and mastery of appropriate job-related skills by a superior within the candidate's organization. All attestations shall be considered final once signed. A defined response form that outlines the necessary and appropriate skills will support attestation as to a candidate’s skill. A high degree of reliance is placed on the attestation forms provided by the applicant’s supervisor when granting certification. For that reason, the individual signing the form should be familiar with the applicant’s experience, performance, and skills/abilities, and confident that the applicant meets all the requirements as noted on the form.

The attestation form addresses the following categories:

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 office suite
• Familiar with data mining/data forensics
• Ability to conduct data analysis, utilizing pivot tables as applicable.

CONCEPTUAL - Provides effective and accurate evaluation of the overall activities of non-bank financial institutions relating money service businesses, including money transmitters, issuers/sellers/redeemers of money orders, traveler’s checks and stored value, check cashers, currency exchangers, and currency dealers:

• Effectively demonstrates knowledge of Money Service Businesses 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 
• Should be aware of the various types of MSBs and the risks involved with each
• Knowledge of state-specific and other call reports
• Knowledge of the Four pillars, reg E and disclosures, financials including the balance sheet, income statement;
• Knowledge of money transmitter rating system; 
• Understanding of net worth vs tangible net worth, what intangible assets are (state-specific); 
• Basic knowledge of BSA/AML; ACN (advance change notice); 
• Must be familiar with the components of the MTRA work program.

LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations, both state and federal, related to Money Service Businesses (Money Transmitters).

• Familiar with state regulations and the industry, kinds of industries regulated (state and federal), and model law;
• A need to have knowledge of the following federal laws and regulations included, including but not limited to:
  • Office of Foreign Assets Control (OFAC) regulations
  • Bank Secrecy Act (BSA): Title 31 USC, Section 5311, as amended by the USA PATRIOT Act and the regulations promulgated there under
  • Title 12, Code of Federal Regulations (CFR), Section 1005.31 (Dodd-Frank)
  • The Consumer Financial Protection Bureau (CFPB) requirements under the Remittance Transfer Rule (subpart B of Regulation E)
  • 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
  • Knowledge of state agent supervision/FINCEN agent list (if available)

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, participants 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.

The following courses and applicable offerings from providers would qualify as continuing education:

• Effective Meetings with Management
• MTRA Annual Conference and Examiner Training
• AMA Effective Technical Writing
• Day One BSA/AML Training
• FFIEC Advance BSA/AML Conference
• NACARA Annual Conference
• NCUA Consumer Compliance Training
• Accounting Essentials/Financial Statement Analysis Course
• Pivot Table Fundamentals
• Fundamentals of Cybersecurity
• Fundamentals of Cryptocurrency
• Association of Certified Anti-Money Laundering Specialists
• Association of Certified Fraud Examiners
• Association of Certified Financial Crime Specialists
• Bank Administration Institute
• Financial Service Centers of America Annual Conference
• Prepaid Card Expo
• FIS: Regulatory University
• Chainalysis
• LinkedIn Learning
• Federal Financial Crime Enforcement Network
• Federal Deposit Insurance Corporation
• Internal Revenue Service
• Federal Reserve Board
• Financial Service Centers of America Annual Conference
• Prepaid Card Expo