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Consumer Complaint Platform to Connect State Regulators and Debt Collection Companies


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The platform includes options for state regulators and the companies that they supervise to track complaints and communicate through a secure, web-based system. The Conference of State Bank Supervisors will hold a webinar on the new system Oct. 8.

10/6/2020 9:00

Accounts receivable management (ARM) industry companies may soon have the opportunity to connect with state regulators about consumer complaints through a new web-based platform called the State Examination Systems (SES), created by the Conference of State Bank Supervisors (CSBS).

SES will operate in many ways like the Nationwide Multistate Licensing System (NMLS), which the CSBS cocreated with the American Association of Residential Mortgage Regulators in 2008.

SES launched with little fanfare in early 2020 as a platform designed to simplify and streamline state-level examinations. In September, the CSBS announced that a “consumer complaint management” feature had been added to SES functionality, allowing state regulators to “enter and process complaints about financial entities under their supervisions.”

According to the CSBS, SES is the “first nationwide platform to bring state regulators and companies into the same technology space for supervision, fostering greater transparency and collaboration. Through SES, state regulators will be able to enhance supervisory oversight of nonbanks while making the process more efficient for regulators and companies alike,” according to a news release.

The CSBS will host a live webinar at 2 p.m. EDT, Thursday, Oct. 8, to provide financial institutions an overview of the SES system and the opportunity for participants to engage, ask questions and get your questions answered.

ACA International’s compliance team followed up with the CSBS for more information on the new platform. Although the CSBS published a map of agencies that will use SES for examinations, consumer complaints, or both, it remains unclear which agencies plan to use SES, including the consumer complaint functionality, to supervise the ARM industry.

As part of the SES, the consumer complaints feature is an end-to-end platform for state regulators and companies to collaborate, execute and participate in the state supervision process. SES staff advised ACA that if and when a participating state regulator needs a regulated entity to communicate with or collaborate with the regulator via SES, the regulated entity will receive a notice from their relevant agency along with instructions on how to create an SES account or otherwise access relevant portions of the SES system.

Through the SES platform, state regulatory agencies will be able to track and manage consumer complaints about financial institutions they supervise and communicate with those institutions about the complaint, according to the CSBS.

It notes the SES platform is not the same as the federal Consumer Financial Protection Bureau’s system, which includes a consumer portal.

Consumers will not have any way to interact with the SES consumer complaints system for some time, according to Lindsay Schmidt, director of SES Business Services for CSBS.

Rather, consumers will use existing means (e.g., mail, phone, internet) to file complaints with state regulators. The regulators will then use the SES system to process, track and communicate with companies about consumer complaints they receive.

Companies licensed or registered through the NMLS will receive SES consumer complaints enrollment information when their state regulator is ready for each company to utilize the new system, according to a news release from the CSBS.  Once registered, institutions will work with their regulator inside the system to resolve consumer complaints.

To date, Hawaii, Idaho, Indiana, Kansas, Maryland, Montana, Nebraska, Ohio, Vermont and West Virginia have opted in to use the platform.

What Companies Can Expect

Companies will be invited to join the SES platform in advance of their first exam or first complaint. Until then, there is nothing a company should do other than be on the lookout for enrollment notifications to the main NMLS or exam/complaints contact, according to Schmidt.

Put simply, SES is replacing the email and correspondence process between companies and regulators and putting all those transactions in a secure, web-based system.

Overall, SES is built to:

  • Support networked supervision among state regulators.
  • Standardize workflow, business rules and technology across states.
  • Facilitate secure collaboration between licensees and their regulators.
  • Help examiners focus more attention on higher-risk cases.
  • Move state supervision toward more multistate exams and fewer single-state efforts.

ACA is continuing to review the new system and will provide any available updates for members and in the meantime recommends members attend the Oct. 8 CSBS webinar. Resources for companies are also available through the CSBS website.

For more information on how the ACA Licensing staff can assist with your licensing needs, please contact us at [email protected] or call (952) 926-6547.

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