Specialty Certification

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 Senior Consumer Protection Examiner (CSCPE) designation must provide evidence of the following:

• Requirements for the CCPE
• Completion of four 4 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 examination requirement:
    • Participation in 15 exams utilizing established examination procedures for both limited and full-scope examinations with minimal supervision.
    • Must have served as EIC or state lead on at least 5 examinations. 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:
  • Requirements for the CCPE
  • AND twenty-eight (28) hours of approved core training (additional core training options can be reviewed upon request)
• 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.

 APPROVED CORE TRAINING OPTIONS

TECHNICAL

Provides effective leadership and organization to the examination process by:

• Effectively supervising personnel to ensure adherence to examination procedures and policies,
• Providing effective training for coworkers and others as appropriate or required,
• Monitoring progress of assigned personnel to ensure accurate and timely completion of work,
• Effectively organizing and delegating assignments,
• Supervising, organizing, and effectively documenting workpapers according to prescribed procedures, and
• Effectively supervising and overseeing the entire examination process
• Awareness of SES.

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

• Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations,

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

• Develops correct conclusions from collected data,

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

• Effectively evaluates and adjusts scope of examination as each situation requires.

• Need to be familiar with the types of Consumer Finance and/ or Debt Collections as applicable including:

  • Auto Finance

  • Secured/ Unsecured Closed End Lending

  • Payday, Title, and Earn-wage access lending

  • Open End Lending

  • Non-mortgage loan servicing

  • Pawn Shop Lending

  • Student Loan Servicing

  • Debt Collections

• Procedures for writing findings and reporting to lead state, Requests for Information; 

• Deeper understanding of emerging technologies; 

• Understanding financials and making sure the financials are certified, notarized;

• Participates in multistate or coordinated exams with federal agencies.
• Acts as EIC or state lead on multistate exams or coordinated exams with federal agencies.

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 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
•  Effectively prepares written comments which are accurate, grammatically correct, logically arranged, and factually support any conclusions drawn,

• Understand how to compose and edit a Report of Examination: put things in context, be clear and concise; ability to issue or finalize report as applicable.

• Effectively conducts meetings with management and/or the boards of directors of licensees,

• Effectively coordinates examination planning and execution with other state and federal supervisory authorities.

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)
• FFIEC Information Technology (IT) Conference 
• FFIEC Information Technology (IT) Symposium
• FFIEC Payment Systems Risk Conference
• FFIEC Supervisory Updates & Emerging Issues for Community Financial Institutions
• FDIC Compliance Training Program – Community Reinvestment Act (CRA)
• 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:

  • Approved Core Training options

  • 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