Specialty Certification

Objectives of the Consumer Protection 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 Certified Consumer Protection Examiner (CCPE)
• Completion of 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 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 examination requirement:
    • Participation in 15 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.)
    • 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
  • In addition to the CCPE training requirements, candidates must complete twenty-eight (28) hours of approved core training from the options listed below. Additional core training options may be reviewed upon request.
• 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.

The following training courses are approved to satisfy the 28-hour core training requirement for the CSCPE. Additional options may be reviewed upon request.

 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 the State Examination System (SES).

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

• 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
  • Closed and Open End Home Mortgage Lending
  • Community Reinvestment Act (CRA) Compliance
  • Home Mortgage Disclosure Act (HMDA) Reporting
• Procedures for writing findings and reporting to lead state, Requests for Information. 
• Deeper understanding of emerging technologies, including but not limited to fintech products, earned-wage access (EWA), buy-now-pay-later (BNPL) lending, digital payments, and AI-driven underwriting or servicing tools. 
• 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.
• Analyzes consumer complaint data to identify trends, systemic risks, and potential violations; incorporates findings into examination planning and scope.

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
  • 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 or 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, 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)
• 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