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 Services Businesses (MSBs) include money transmitters; virtual currency exchangers/wallets/kiosks, 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 Services Business area of the regulation.
• To emphasize the need for professionalism and continuing advancement of Money Services 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 Services 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 (BSA) and Anti-Money Laundering (AML) regulations as it relates to MSBs.
• Participation in at least four (4) examinations utilizing established Money Transmitter Regulators Association (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 MTRA work program.
• Satisfactory completion of the following course offerings or their equivalent:
  • CSBS Day One MSB Examiner Course (online) and
  • MTRA Operations School

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 the training of coworkers and colleagues as appropriate and necessary
• Supervises, organizes, and effectively documents workpapers according to prescribed procedures
• Familiar with Microsoft Office suite of applications
• 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 to money services businesses, including money transmitters, virtual currency exchangers/wallets/kiosks, currency dealers/exchangers; check cashers; and issuers, sellers or redeemers of traveler’s checks, money orders, or stored value products.

• Effectively demonstrates knowledge of Money Services Businesses policies, procedures, laws, rules and regulations – both state and federal
• Knowledge of MTRA ROE composite rating system
• Effectively follows established and accepted examination procedures to collect and analyze data
• Preparation of written comments is factually and technically correct
• Effectively reviews reports of examination for accuracy, content, conclusions, and proper grammar
• Must be familiar with the components of the MTRA work program
• Workpapers support the report of examination (ROE) with detailed information and provide a clear audit trail
• Should be aware of the various types of MSBs and the risks involved with each
• Knowledge of the five pillars of BSA/AML compliance, Regulation E, and the Consumer Financial Protection Bureau (CFPB) disclosures
• Knowledge of (un)audited financials including the balance sheet, income statement, cash flow statement, and statement of changes in shareholders’ equity
• Understanding of net worth vs tangible net worth, what intangible assets are (state-specific)
• Knowledge of state-specific and other call reports.

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

• Familiar with state regulations and the industry, kinds of industries regulated (state and federal), and model law (the CSBS Money Transmission Modernization Act, or MTMA);
• A need to have knowledge of the following federal laws and regulations included, including but not limited to:
  • Office of Foreign Assets Control (OFAC)
  • 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)
  • 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 (Financial Crimes Enforcement Network) agent list (if available)
  • The GENIUS Act of 2025 (payment stablecoin framework), including the federal and state issuer pathways and preemption of state licensing for permitted payment stablecoin issuers.

COMMUNICATIONS - Provides effective oral and written communications:

• Effectively communicates assignments to assisting examination personnel
• Effectively communicates with licensee senior management, personnel to obtain information
• Effectively communicates with other state and federal 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 (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 courses and applicable offerings from providers would qualify as continuing education:

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