Multi-State Regulatory Groups Issue Annual Reports to State Regulators
On April 27, 2015, the Conference of State Bank Supervisors (CSBS) announced the publication of three annual reports produced by multi-state regulatory groups, including the State Coordinating Committee (SCC), the Multi-State Mortgage Committee (MMC), and the Multi-State MSB Examination Task Force (MMET). In particular, the publication of the STATE COORDINATING COMMITTEE REPORT TO STATE REGULATORS 2014 details much of the work that NACARA members have been engaged with the SCC since the latter half of 2013.
The SCC was formed as the official state coordinating body under the 2013 CFPB-State Supervisory Coordination Framework. The SCC is comprised of two representatives from each of the six state financial regulatory associations: Conference of State Bank Supervisors (CSBS); American Association of Residential Mortgage Regulators (AARMR); Money Transmitter Regulators Association (MTRA); National Association of Consumer Credit Administrators (NACCA); North American Collection Agency Regulatory Association (NACARA); and National Association of State Credit Union Supervisors (NASCUS).
The SCC is responsible for:
- Annually developing a list of proposed coordinated examination targets and working with the CFPB to identify a final list of companies to be examined and the agreed examination start dates;
- Annually providing the CFPB with notice of any independent examinations and proposed examination schedules for the following year;
- Quarterly reviewing the schedules and updating as needed; and
- Designating state single points of contact and examiners in charge for each coordinated examination.
Below are some of the highlights from the SCC’s annual report:
- The SCC and CFPB held their first annual meeting in October 2013, and held six in-person meetings throughout 2014.
- The SCC and CFPB conducted nine joint examinations of non-depository, multi-state companies in 2014.
- Six of these exams were of mortgage companies and covered both origination and servicing functions. A total of 35 states and 129 state examiners participated in the coordinated mortgage exams in 2014.
- One coordinated payday lending examination was conducted in 2014, involving four states.
- Two debt collection exams were conducted in 2014, with seven states participating.
- Began development of coordinated examination procedures.
- Facilitated the delivery of information between the CFPB and state regulators.
The CSBS press release is linked above but can also be accessed at http://www.csbs.org/news/press-releases/pr2015/Pages/PR-042715.aspx. The SCC annual report is also linked above but copies of all three multi-state regulatory group reports can be accessed at: http://www.csbs.org/news/presentations/annualreports/Pages/nondepreports.aspx.