To All MTRA Member States:
The 2005 MTRA Annual Conference in Charleston, SC last week was a huge success. It seems that every year the conference is better than the year before. For two years, President Phil Goddard has led the 35 or so member states in a cooperative effort to improve regulation and examination of the money transmission industry. During this time period, healthy and constructive dialogue between the industry and the regulators has allowed each side to have a better understanding of the other. The examination committee has made significant strides in realizing our goal to provide a more seamless examination product.
With these successes in mind, we must look ahead and challenge ourselves to improve the process that we began when we signed the cooperative agreement. I would like to set certain goals for the MTRA for the next two years.
1. Examination Committee – Establish the use of one core examination report that all member states find acceptable. All examiners have the same objectives when examining a company. It is clear that we use different methods to achieve these objectives. I know from past experience with our bank and credit union examiners who have already been through this process that states often do not like to give up what they perceive as “their way”. Now is the time to prepare this new Core Examination Report and gain acceptance for use by each member state. The 15 or so states that currently perform examinations are the likely candidates to undertake this review. No state should have to give up what they consider important exam information or data. Some states might have to accept a more detailed report than what is currently accepted. With the use of state-specific sections, all states will be able to meet their particular requirements. The industry will also benefit by understanding one examination format.
2. Ratings System – Those of us who are familiar with examination ratings systems know that the language between different groups can be bridged by the use of a common acceptable rating system. Examinations should produce a way for all readers to measure the different aspects of the operations of a company. After producing a core report, a rating system is the next logical step.
3. Examination School – As individual state regulators, we know the value of training our examination staffs’ to become proficient in their particular areas of expertise. The MTRA examiners school was formed several years ago as part of our annual conference. The schools have been praised by the attendees as providing valuable, timely and current information that can instantly be used as part of examination procedures. Bert Gonzales of Texas and John Bishop of Ohio have been invaluable to our examination school. When a state makes the decision to begin examining money transmitters, where can they turn to train a new examiner? Historically, you either trained your own people or asked other states if they could have a new employee tag along to learn the techniques. This approach does allow the student to see different methods but it is not a consistent training technique that the industry needs as it tries to operate across state lines. The industry comments I received at this year’s conference confirmed my belief that consistency in examination findings are needed. How can we produce a universal examination program that flows seamlessly from state to state? I believe the MTRA needs to establish an Introductory Exam School for new money transmitter examiners that last at least 4 days held at least once a year. A second school for advanced examiners should also be established annually to discuss current topics and more advanced techniques. These schools do not necessarily need to be attached to the annual conference.
I believe these goals can be accomplished with input from all involved states and the Board of Directors of the MTRA. Once they are achieved, our examination product will improve greatly and the industry will appreciate the efficiencies that we bring to the examination process. I look forward to working with all member states and the industry to improve and build on our past accomplishments. I am sure the 2006 Annual Conference in Santa Fe will be as successful as the Charleston conference.
Sincerely,
Joseph E. Rooney
Deputy Commissioner
State of Maryland