On April 3, 2023, the Conference of State Bank Supervisors (CSBS) released an update on the status of its State Examination System (SES). The SES is an examination system that is intended, in part, to foster standardization and enable state-level coordination by providing a platform for state agencies, regulators, and companies to conduct company exams from start to finish.
Launched in 2020, the SES allows state regulators to schedule exams, jointly track exam progress, and coordinate on exams across states. For instance, the SES would allow coordinating state agencies to make a single document request to a company, and also provide the company with a single location to which it could upload the requested files. These files could then be viewed by agency examiners participating in that multistate exam. Such coordination is intended to result in less burdens placed upon companies, by way of fewer concurrent exams and duplicate requests for information. With the exception of Florida and Utah, all states currently use SES for either their supervisory activities or for their complaints process (or both) in at least one state agency. CSBS states that over 3,800 exams have been conducted to date through the SES.
CSBS notes that the “SES already include[s] common exam standards for mortgage companies, debt [collection] companies and money services businesses. With the new consumer finance standards added to the suite of SES exam standards, state agencies can … achieve a more uniform process and minimize the need for companies to respond to differing, state-specific exam standards.” Further, the hope is that these standards will lead to even more state agencies coordinating exams via the SES.
Additional information about the SES can be found on the CSBS website