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.
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
- Effectively conduct a PEP interview
- Identify inherent risk based on findings from background research and pre-exam interview
- Review HMDA validation results for any issues that merit inclusion in the ARCH
- Assess potential third-party risk during PEP
- Assess potential UDAP risk during PEP
- Identify what documents and information to request in CIDR based on PEP interview and other information
- Conduct preliminary CMS assessment
- Identify products, services, and regulations to include in the examination scope
- Identify what documents and information to request for your Transactional Testing
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
No continuing education credits.
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.
There should be a minimum of six months between attending IFLS and SCOPE.
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 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 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.
- Conduct background research
- Participants will review background information on the case study bank including review of the last examination Assessment of Risk of Consumer Harm (ARCH), Uniform Bank Performance Report (UPPR), Compliance Report and RMS Report of Examination, and begin to develop the risk profile for the bank by identifying inherent risks.
- Conduct and Tailor PEP Interview
- Participants will observe a Pre-Exam Planning (PEP) interview and identify how PEP interview questions were customized; tailor PEP interview questions based on the case study bank’s background information and interview an instructor.
- Prepare and review Compliance Information and Document Request (CIDR)
- Participants will create a CIDR using a list of potential informational questions related to Lending and the inherent risks identified for the case study bank.
- Prepare the ARCH
- Participants will review all sections of the ARCH for the case study bank and determine if the inherent risks will be a PSR.
- Review third party relationships
- Participants will review descriptions of third-party products and services (e.g. Third Party Payment Processors (TPPP), broker relationships, debit card programs) and determine the potential risks associated with them.