Specialty Certification

Certified Senior Trust Examiner (CSTE) 

Objectives of the Senior Trust Examiner Certification Program:

  • To achieve recognition of advanced specialized knowledge, skills, and abilities required for the examination of trust institutions of all sizes and complexities to ensure their compliance with state and federal laws and applicable regulations.
  • To promote continuing education in trust supervision, ensuring that examiners remain knowledgeable about evolving practices, regulations, and standards within the trust and fiduciary industry.
  • To emphasize the need for professionalism and continuing advancement of trust 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 CSTE designation must provide evidence of all of the following:

  • Completion of a minimum of four (4) years of trust examination experience. Equivalent industry experience may be substituted on a case-by-case basis.
  • Participation in at least 5-6 examinations as EIC, three of which are complex institutions. Please provide details of the size and type of accounts of the trust institutions examined in the application information.
  • Satisfaction of the requirements for the Certified Trust Examiner (CTE) designation.
  • Satisfactory completion of the following course offerings or an equivalent (courses submitted for equivalency will be considered on a case-by-case basis):
    • 28 total hours of advanced trust training such as:
      • CSBS Trust Forum
      • FFIEC Asset & Wealth Management Forum
      • Advanced trust training at the Cannon Financial Institute or Campbell University (NC), or other recognized professional training program, or
      • A postgraduate university degree in a program focused on trust management and compliance.
    • AND Leadership training such as:
      • CSBS Leadership Effectiveness and Development (LEAD)
      • CSBS Examiner-in-Charge School

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.

The attestation form addresses the following categories:

TECHNICAL - Provides effective leadership and organization to the examination process:

  • Effectively supervises assisting personnel to ensure adherence to examination procedures and policies.
  • Provides effective training for coworkers and others as appropriate or required.
  • Effectively organizes and delegates assignments.
  • Monitors progress of assisting personnel to ensure accurate and timely completion of work.
  • Supervises, organizes, and effectively documents workpapers according to prescribed procedures.
  • Effectively supervises and oversees the entire examination process.
  • Awareness of SES.

CONCEPTUAL - Provides effective and accurate evaluation of the operational, financial, and investment activities of large and/or complex non-depository trust institutions and bank trust departments:

  • Effectively demonstrates understanding of applicable codified laws, rules, and regulations as well as agency policies and procedures, industry standards, and best practices.
  • Effectively follows established examination procedures to collect and analyze data.
  • Develops correct conclusions from collected data.
  • Effectively evaluates and adjusts the scope of examinations as each situation requires.
  • Demonstrations understanding of trustee and fiduciary duties.
  • Demonstrates understanding of the Uniform Interagency Trust Ratings System (UITRS) and the trust examination components: Management; Operations, Internal Controls and Auditing; Earnings; Compliance; and Asset Management.
  • Demonstrates knowledge of various types of trust institutions and accounts, including: 
    • Revocable and Irrevocable Trusts
    • Trusts with Discretionary, Delegated, and Directed Investment Authority
    • Charitable Trusts and Foundations/Endowments
    • Special Needs and Settlement Trusts
    • Life Insurance Trusts
    • Retained Interest and Lead Interest Trusts
    • Guardian/Conservator Appointments
    • Cemetery/Pre-Need Funeral and Estate Accounts
    • Employee Benefit / Retirement Accounts
    • Escrow and Corporate Trust Accounts
    • Agency and Custody Accounts
    • Collective Investment Funds and Common Trust Funds 
  • Demonstrates knowledge of the diverse array of assets that might be managed or administered by trust institutions.
  • Demonstrates familiarity with emerging topics and their implication to the trust examination process, such as the evolving regulatory landscape, foreign asset/account characteristics and domestication, fintech vendors and portfolios, crypto asset and blockchain technology, etc.

LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations.

  • Demonstrates understanding of applicable trust-related state laws and regulations.
  • Demonstrates knowledge of other potentially applicable industry standards for fiduciary activity as promulgated via model or uniform acts/laws, including the Uniform Trust Code, Uniform Directed Trust Act, Uniform Prudent Investor Act, Uniform Principal and Income Act, etc.
  • Demonstrates understanding of the interaction between state and federal laws, rules, and regulations for various types of trust institutions. 
  • Demonstrates knowledge of applicable federal laws and regulations, which may include but are not limited to:

    • Office of Foreign Assets Control (OFAC) regulations 

    • Bank Secrecy Act and Anti-Money Laundering (BSA/AML) regulations 

    • Customer Identification Program (CIP) regulations 

    • FDIC Statement of Principles of Trust Department Management 

    • Employee Retirement Income Security Act (ERISA) regulations 

    • 12 CFR 9 Fiduciary Activities of National Banks 

    • 12 CFR 17 Part 247 Regulation R (Exemption for Banks from the Definition of Broker)

  • Demonstrates knowledge of applicable legal/business entity, property, and tax laws, rules, and regulations.

HUMAN RELATIONS - Provides effective oral and written communications:

  • Effectively and clearly communicates assignments and expectations to assisting personnel.
  • Effectively collaborates with assisting examination personnel to organize and analyze examination information and materials in a timely and professional manner.
  • Effectively and clearly communicates with trust institution personnel to obtain information.
  • Effectively conducts meetings with the boards and management of trust institutions in an organized and professional manner.
  • Effectively and clearly communicates examination findings to trust institution management and to agency supervisory personnel.
  • Effectively prepares written comments which are accurate, grammatically correct, logically arranged, and factually support any conclusions.
  • Effectively composes and edits reports of examination to be clear and concise, maintain appropriate context, and finalized or issued in a timely manner.
  • Effectively communicates with other regulatory agencies regarding examination logistics, information requests, findings, resolutions, etc.

Trust Recertification

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

  • Courses/Seminars
    • CSBS Trust Forum
    • CSBS LEAD (formerly known as Senior School)
    • CSBS BSA/AML Examiner School
    • CSBS Examiner-in-Charge School

    • CSBS Effective Meetings with Management 

    • FIRMA National Training Conference
    • Trust Advisors Forum (Campbell University)
    • FFIEC Asset & Wealth Management Forum 

    • FFIEC Advanced BSA/AML Specialists Conference 

    • FFIEC Anti-Money Laundering Workshop 

    • Cannon Financial Institute - Hard-to-Value Assets 

    • Chainalysis Cryptocurrency Fundamentals

    • Other programs approved on a case-by-case basis
  • Other relevant leadership or trust-related training from recognized providers, such as:

    • Conference of State Bank Supervisors (CSBS)

    • Federal Financial Institutions Examination Council (FFIEC)

    • Federal Deposit Insurance Corporation (FDIC)

    • Federal Reserve Board (FRB)

    • Office of the Comptroller of the Currency (OCC)

    • Federal Financial Crime Enforcement Network (FinCEN)

    • Internal Revenue Service (IRS)

    • Cannon Financial Institute

    • Northwestern University Trust School

    • State Bankers Associations

    • American Bankers Association (ABA)

  • Other relevant training pertaining trust-related topics, such as:

    • Individual Retirement Accounts (IRAs)

    • Custody and Safekeeping Accounts

    • Corporate Trusts

    • Crypto Assets

    • Portfolio Management

    • Securities Transactions and Operations

    • Gift and Estate / Transfer Taxes

    • Bank Secrecy Act / Anti-Money Laundering (BSA/AML)

    • IT / Cybersecurity

Nontraditional credit for speaking, authoring, teaching, etc. approved on a case-by-case basis.