Program Overview
Scoping and Planning for Examinations School is presented in a virtual delivery format and addresses the pre-exam planning process, beginning with the Information Package through conducting the analysis for completion of the Assessment of Risk of Consumer Harm (ARCH). The focus of the course is on developing the examiner's analytical skill in planning for risk-focused compliance examinations based on the potential for consumer harm. The course consists of lessons, group exercises, and a case study that takes the students through scoping an examination step by step, including the creation and presentation of an ARCH memorandum. Participants actively take part in group case studies and other classroom activities.
Skills Taught
By the end of this course, students will have been taught how to:
- Draw the connection between the consumer protection laws and regulations and the concepts of consumer harm and risk scoping for examinations
- Conduct background research for an examination
- Assess potential third-party risk during pre-examination planning (PEP)
- Conduct a PEP interview
- Identify inherent risks based on background research and PEP interview
- Assess and describe the importance of UDAP risk analysis during PEP Identify documents and information to request in the CIDR based on PEP Interview results and other information
- Review and conduct the bank’s preliminary compliance management system (CMS) using off-site information
- Identify products, services, and regulations (PSRs) to examine onsite
- Review and describe the overall process involved in Home Mortgage Disclosure Act (HMDA) validations
- Identify and create a list of Transactional Testing documents to request
Duration and Format
This course contains:
- 16 hours of Pre-Course Work
- Readings and an assignment.
- 1-week Facilitated virtual classroom discussions/lectures
- Small group activities
- In-class project
Levels and Credits
Basic
Continuing Education Unit (CEU): 2.2*
Continuing Professional Education Unit (CPE): 25.8*
*Currently, we are unable to track and provide documentation for credits.
Target Audience
FDIC participants should attend in accordance with the parameters outlined in the Examiner Training and Development Policy. State Banking Authority participants should have 17-21 months of experience in compliance examinations. This course is open to appropriate staff of the FDIC and partner government regulatory agencies. This course is not open to the public or staff of private banks.
Prerequisites and Prior Work Experience
Prior to attending the course, participants must have satisfactorily completed and have a working knowledge of the following:
- The Introduction to Consumer Protection School (or have compliance mid-career examiner status)
- Introduction to Fair Lending School.
- Fair Lending Analysis and Review (FLARe)
There should be a minimum of four months between attending FLARe and SCOPE.
Pre-Course Assignment
The items below constitute the pre-course assignment. The pre-course assignment is due in general two weeks/11 business days prior to the start of the session. The exact date the work is due for any given session is specified in the pre-course information sent approximately two months prior to the start date. Prior to attending the workshop, participants are required to complete and submit the following pre-course assignments:
- Read the ARCH Reference Guide and answer questions.
- Read Compliance Manual section 11-3.1 Compliance Management System and answer questions.
- Read certain case study materials and answer questions to become familiar with the case study bank.
NOTE: The Division of Depositor and Consumer Protection (DCP) has authorized 16 hours of official time to complete the pre-course assignment.
Post Course Recommendation and Feedback
Participants should be scheduled to complete pre-exam planning for an examination as soon as possible (under Examiner-in-Charge oversight) after completing this course to reinforce the skills learned from this session. If possible, the participant should also shadow that same Examiner-in-Charge (EIC) throughout the examination to see how pre-exam planning shapes the on-site examination.
To help practice and apply the knowledge and skills learned in SCOPE School, the participant should complete the pre-exam planning tasks listed below with oversight by an EIC:
- Conducting background research
- Conducting Pre-exam Planning Interview
- Preparing and reviewing CIDR
- Preparing the ARCH
- Preparing Transactional Testing Request
A Summary Evaluation Form, which provides a comprehensive discussion of the participant's in-class and project exercises, is sent to the participant's field office approximately thirty days after the conclusion of the school. Within the Summary Evaluation Form, participants will also receive individual feedback on the in-class Products, Services, or Regulations (PSR) Comment writing assignment.
NOTE: Participants should get additional practice in all of these areas soon after completing the school.
Key Topics
- Consumer Harm and Risk Scoping – Explain the concept of risk scoping; draw the connection between the consumer protection laws and regulations, concepts of consumer harm and risk scoping for examinations; and determine risk levels of various products and assess how controls impact the risk level.
- Third-Party Risk – Assess potential third-party risk during PEP; explain the use of third-party relationships and its impact on consumer harm and compliance examinations; and how to identify significant third-party relationships.
- UDAP Risk – Assess potential UDAP risks and apply the standards for unfair and/or deceptive acts or practices.
- PEP Interviews and CIDR – Tailor PEP interview questions based on background research and identify documents and information to request in the CIDR based on the PEP interview responses.
- Examination Scope – Determine if a bank’s CMS mitigates inherent risks; describe the process for determining PSRs for review; and propose PSRs to examine through analysis of inherent risks and mitigating factors.
Continuing Education Information
For information regarding administrative policies such as complaints and refunds, please contact Corporate University, Attn: NASBA Representative Ava Livas, Room A-3025, 3501 North Fairfax Drive, Arlington, VA 22226 (703) 562-2463.
The Federal Deposit Insurance Corporation is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBARegistry.org
The Federal Deposit Insurance Corporation (FDIC) is accredited by the International Association for Continuing Education and Training (IACET) (www.iacet.org). The FDIC complies with the ANSI/IACET Standard, which is recognized internationally as a standard of excellence in instructional practices. As a result of this accreditation, the FDIC is accredited to issue the IACET CEU.
More Information
For more information concerning course content and administration, contact Pamela Sweeney or Helen Briggs.