Agency Library: Key Concepts, Features, and Management

This policy addresses the management of the State Examination System (SES) Library and defines the Library’s terminology and functionality.

Approved 3/24/2020

Updated: 2/23/2024

The Library is a feature of SES designed to carry out two main functions in the system:
  1. Maintain the core components of any exam program (e.g., information requests, procedures, and references) allowing users to easily access and use these materials while conducting a supervisory activity.
  2. Automate the development of an exam record by allowing the system to retrieve (from the Library) and insert information requests and procedures applicable to the scope of the exam directly into an exam record.

To maximize the automation SES provides in the exam workflow, agency users must become familiar with the terminology and functionality of the Library. It is recommended that agencies appoint at least one agency representative to become familiar with the Library (a librarian of sorts), its components, and to become proficient in the regular maintenance of agency-specific Library items.

Only agency users and support users have access to the Library in SES. Company users cannot access the Library. To maximize the automation SES provides in the exam workflow, agency users must become familiar with the terminology and functionality of the Library. It is recommended that agencies appoint at least one agency representative to become familiar with the standard items (as defined below) in the Library and proficient in the creation and ongoing management of agency-specific Library items. The following sections define the terminology and functionality of the Library.

Library Components

The Library houses the following Library item types:
  • Area for ReviewA topic of regulatory review that can be used to define the scope of an examination or investigation. It assists in categorizing the Information Requests and Procedures in an examination.
  • ProceduresEntries used to guide examiners during the examination in the review of company documentation or compliance with statutes, regulations, and other requirements.
  • Information RequestsEntries used to request information and documentation from a company for the examination. In SES, the IRs are divided into “standard” requests and “state-specific” requests.
  • ReferencesWorkpapers, templates, websites, and/or any other supplemental reference material that an agency may choose to use used to support the supervision process, and to better navigate SES.

In addition, the NMLS Business Activities are an important item of the SES Library structure. The NMLS Business Activities are generic, non-legal definitions of a financial services activity that reasonably describes the activity1. They are categorized by product types (e.g., mortgage, consumer finance, debt). In SES, Business Activities assist with the mapping and categorization of the IRs and procedures housed in the Library.

Standard vs. State-Specific Library IRs and Procedures

Two Library components, the IRs and procedures, are furthered separated into two categories in the system 1) standard IRs and procedures, and 2) agency-specific IRs and procedures.

  • Standard IRs and ProceduresThese items are available in SES to facilitate the harmonization of exam activities among state agencies, by offering a uniform set of information requests and procedures for use by all state agency users. CSBS works and coordinates with its sister trade associations and agency working groups to implement, maintain, and update the standards in the system.2
    • User Access:
      • Agency Users can review the standard information requests and procedures, but only CSBS staff can manage the standard library items (to edit, retire or updated them).
      • Company Users can review the standard information requests only via the SES QuickIR feature. They can respond to a standard IR and save it in QuickIR for future use in an exam. Company users cannot edit the IRs or see agency-specific items.
  • Agency-Specific Library ItemsAgencies can manage their own state-specific IRs, procedures, and references. These state-specific items should be unique or different from a standard library item, whereby the agency cannot rely solely on the standard.
    • User Access:
      • Currently, only the individual agency has the permission to add and manage agency-specific library items.
      • Other agencies can see the state-specific procedures and IRs.
      • Agency-specific references are not automatically accessible by other agency users. However, the agency has the option to share references with other agencies.
      • Company users cannot see agency-specific IRs, procedures, or references.

Important Library Labels

  1. Scope Type

    The scope type covers the ranges of reviews that will be conducted on the company. The standard scope types include the Full scope type and the Networked scope type. The standard information requests and procedures in the system are tagged under both scope types.

    • Full scope type. Used by an agency when conducting a complete examination on a company.
    • Networked scope type. Used by an agency when directly coordinating an examination in the system with another agency.
    Other scope types remain undefined in the system to allow agencies the flexibility to use them when needed depending on their state-specific mandates and requirements.
  2. Core vs. Non-core Library Labels

    Core and non-core labels are attributes associated with information requests and procedures that control whether these items will be automatically retrieved from the library and inserted directly into an exam record given the exam’s business activities and scope selections.

    • The core designation can be applied to both standard and agency-specific procedures and information requests.
      • CSBS staff, with guidance from the appropriate governing bodies, manage the scope types for the standard IRs and procedures.
      • Agencies manage the scope types for their own state-specific library items.
      Core Information Requests are automatically pulled on to an exam or investigation once scope is marked complete. Core procedures are automatically pulled on to an exam or investigation once the supervisory activity is moved to the “In-Flight” milestone. Attributes the system uses to make this determination:
      • Scope Type
      • Business Activities
      • AFR
    • Non-core Procedures and Non-core Information Requests will not be automatically added to an exam or investigation, but can be easily added if appropriate. Attributes the system uses to determine IRs and procedures available for quick add:
      • Scope Type
      • Business Activities
      • AFR

Guidelines for Agency Users

Agency users will find numerous supervision resources available to use in the system in the form of standard Library items. By making these resources available to all agency users there is an opportunity to cultivate harmonization and areas of uniformity throughout the state regulatory system.

Agency users are strongly encouraged to use the standards wherever possible. State-specific items should be uploaded to the system with limited exceptions and should be regularly maintained by the state agency. Agency users should evaluate the standard information requests and procedures in the system to identify similarities to their agency’s template information request lists and procedures. To the extent a standard information request or procedure in SES is similar to what the agency is currently using, the agency should use the standard library item.

In the mortgage area, CSBS supports agencies’ assessments of state-specific IRs that are needed in SES before they are uploaded to the system (i.e., the filter process for mortgage state-specific IRs)3. This process was implemented to avoid redundancies and duplications, and with the support of the SRR Board of Managers. Refer to Filter Process for State-specific Mortgage Information Requests for more information.

By leveraging the standard information requests and procedures across the agencies using SES, the companies being examined through the system will become familiar with these standard items over time and allowed to maximize the use of QuickIR. Creating this familiarity with the standards will produce consistent expectations for companies examined by multiple agencies through SES.

Additional Library Guidelines

  1. If the agency determines that state-specific information requests are needed, agency users should avoid consolidating multiple requests for information into a single information request. This practice makes it challenging for the company user to respond as they have a single text box along with one area to upload documentation.
  2. Agency users should never upload or include any confidential supervisory information to any library item.

Document Retention for the Library

All documents uploaded to the library will remain in the library until CSBS staff retires the standard, or an agency user retires a state-specific IR or procedure.

2 Sister trade associations include but are not limited to the Money Transmitter Association, the Multistate Mortgage Committee, the National Association of Consumer Credit Administrators, and the North American Collection Agency Regulatory Association.
3 Currently, the filter process is applicable to mortgage state-specific IRs only.