New certification which will be effective July 1, 2024.

Candidates for the CMMBE designation must provide evidence of the following:

• Completion of a minimum of 5 years’ 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, and review of compliance with Bank Secrecy Act and Anti-Money Laundering regulations.
• Participation in nine exams as EIC with four of them being the lead state on multistate examinations over a three-year period.
• Satisfactory completion of the following course offerings or their equivalent:
  • Course requirements for the CMBE and the CSMBE designation, and
  • MTRA Senior School, and
  • CSBS LEAD or Examiner-in-Charge School, and
  • SME knowledge in at least one area - BSA, IT, crypto, etc. This requirement can be fulfilled with IT Examiner School, cybersecurity or crypto training OR BSA School OR equivalent
• Attestation of successful job performance and mastery of appropriate job-related skills by a supervisor within the candidate's organization. All attestations shall be considered final once signed. Attestation as to a candidate's skill will be supported by a defined response form that outlines the necessary and appropriate skills. 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 should be 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: 

• Effectively supervises personnel to ensure adherence to all procedures and policies; 
• Monitors senior examination personnel to ensure examination mission, goals, and responsibilities are being met; 
• Effectively organizes and delegates assignments; 
• Effectively supervises the entire examination process, including pre-examination scoping and planning, and flow of work and documents during the examination. 
• Participates in review scoping and scheduling and participates in scheduling calls where applicable.

CONCEPTUAL - Provides effective supervision of the overall activities of MSBs in a multistate setting:

• Effectively determines a multistate MSBs condition from completed reports of examination; 
• Effectively administers appropriate departmental response from examination findings and follow-up on correction of problems and violations. 
• Understanding of responsibilities and roles (Management); 
• Components of the MTRA work program: should be efficient in every tab and able to complete any tab; 
• Skilled at managing people, managing the exam and the licensee; 
• Understands risk - ex. volatility of the crypto market; 
• Basic understanding of capital markets.

LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations and participates in development of amendments to laws or new legislation as applicable:

• Effectively demonstrates knowledge of applicable federal and home state laws related to Money Service Businesses (Money Transmitters); 
• Effectively demonstrates knowledge of policies, procedures, rules and regulations; 
• Effectively reviews violations and approves corrective action or enforcement powers related to findings;
• Maintains advanced knowledge of state statutes and applicable federal laws and regulations; 
• Should be able to complete all sections of the joint program as applicable.

HUMAN RELATIONS - Recognizing the increased scope and complexity of multistate MSB examinations, applicant must have higher level interpersonal and communication skills, such as:

• Effectively provides for personnel management in the areas of budgeting, recruiting, training, team-building, negotiation, motivation, coaching and counseling, performance evaluation, and disciplinary actions; 
• Effectively and clearly communicates orally and in writing with people and organizations internal and external to the department, including examiners in other states' agencies and the MTRA; 
• Effectively conducts meetings with management, owners and the boards of directors of multistate MSBs;
• Effectively coordinates multistate MSB examination planning, execution and regulatory response with other state and federal supervisory or law enforcement authorities; 
• Understands how to write an ROE, put things in context, and be clear and concise; 
• Has skills in negotiation, conflict resolution, and emotional intelligence.

RECERTIFICATION

Every three years, certified examiners are required to submit 40 continuing education hours (CEHs) in order to renew a CMMBE certification. 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. 

Additionally, renewal is dependent participation on 9 exams in 3 years with 4 of those being EIC on multistate examinations.

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

• MTRA Annual Meeting & Examiner’s School
• NCUA Consumer Compliance Training
• Applicable portions of Annual Conferences or other seminars, not utilized for minimum certification requirements, of:
  • CSBS
  • NMLS
  • MTRA
  • NACARA
  • ACAMS
• Federal Financial Crime Enforcement Network
• Federal Deposit Insurance Corporation
• Internal Revenue Service
• Federal Reserve Board
• 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
• Global Financial Markets Institute Classes