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/or examiner in charge to determine compliance with applicable state and federal consumer protection laws and regulations in any business or financial institution that provides financial services to consumers, such as consumer finance companies, debt collection companies, or other regulated entities, as applicable, as follows:
    • Participation in 10 exams utilizing established examination procedures for both limited and full-scope examinations with minimal supervision. (Limited-scope examinations focus on specific areas of risk or compliance; full-scope examinations cover all applicable consumer protection laws and regulations.) 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 the following course offerings or equivalent:
    • Introduction to Consumer Finance Training (online) Candidates must complete all courses, which are grouped as a curriculum in the CSBS learning management system.
      • Note: All courses within the linked training curriculum are required for certification. Candidates should confirm the current course list and estimated completion time with CSBS prior to applying.
    • AND two of the following courses provided by NW3C:
      • Financial Investigations Practical Skills (FIPS)
      • Financial Records Examination and Analysis (FREA)
      • Financial Records Investigation Skills (FRIS)

Applicants must ensure that they meet all certification requirements and will then complete an attestation of successful job performance and mastery of job-related skills, providing a thorough written response for each competency category. Their supervisor will then review and affirm the attestation to ensure accuracy and completeness. The core competencies are an integral part of the certification, and a high degree of reliance is placed on the attestation for determining compliance with these skill areas. The supervisor reviewing the application form should be familiar with the applicant’s experience, performance, and skills/abilities and be confident that the applicant meets all the requirements outlined in the form.

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.
  • Ability to conduct data analysis.

CONCEPTUAL – Provides effective and accurate evaluation of the operational and financial activities of companies and financial institutions providing consumer financial services:

  • Provides effective and accurate evaluation of the overall activities of companies and financial institutions relating to consumer compliance, consumer finance and debt collection business activities.
  • Effectively demonstrates knowledge of consumer protection, consumer compliance, consumer finance, or debt collection policies, procedures, laws, rules and regulations – both state and federal, including Community Reinvestment Act (CRA) where applicable
  • Effectively follows established and accepted examination procedures to collect and analyze data.
  • Preparation of written comments is factually and technically correct.
  • Workpapers support the 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, financial institutions, and other regulated entities and the risks involved with each.
  • Awareness of Community Reinvestment Act (CRA) requirements and Home Mortgage Disclosure Act (HMDA) reporting obligations as applicable to the regulated entity.
  • Understands the role of consumer complaints in the examination process, including how to identify patterns of potential violations and incorporate complaint data into examination scope.
  • 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
    • 42 U.S.C. § 3601- Fair Housing Act (FHA)
    • 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) (apply provisions currently in effect)
    • 12 CFR 1003- Regulation C (Home Mortgage Disclosure Act)
    • 12 CFR 1013- Regulation M (Consumer Leasing Act)
    • 12 CFR 1014- Regulation N (Mortgage Acts and Practices)
    • 12 CFR 1024- Regulation X (Real Estate Settlement Procedures Act)
    • 12 CFR 1030- Regulation DD (Truth in Savings Act)
    • Regulation CC - Availability of Funds and Collection of Checks (12 CFR 229)
  • 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
  • 42 U.S.C. § 4012a / 12 CFR Part 339- Flood Disaster Protection Act (FDPA)

COMMUNICATIONS – Provides effective oral and written communications:
 

  • Effectively communicates assignments to assisting examination personnel.
  • Effectively communicates with financial institution, company, 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.
  • Prepares written examination findings that are factually accurate, grammatically correct, logically organized, and supported by workpaper documentation.
  • 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 (CEH). If an examiner exceeds this requirement, up to 14 CEHs may be carried over into the new three-year term. Continuing education should be selected with the goal of maintaining, improving, or expanding the examiner’s knowledge, skills, and abilities. Participants are also required to review and remain in compliance with updates to certifications. Should a material change related to the certification occur, additional training may be required to maintain certification.

The following are approved continuing education options for recertification. Participants should select training that maintains, improves, or expands their knowledge, skills, and abilities in consumer protection examination:

  • CSBS Leadership Effectiveness and Development (LEAD)
  • FDIC Compliance Training Program – Community Reinvestment Act (CRA)
  • FDIC Introduction to Consumer Protection School
  • FDIC Introduction to Fair Lending
  • FDIC Fair Lending Analysis and Review
  • 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 (course availability subject to change):
    • 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