บทถอดความฉบับเต็มของ In the Loop Episode 5 | Inside MSB Supervision: A View from the Other Side of the Exam

Give me the bobber and some worms, and that's about all I can do. I definitely don't have that skillset, so that is impressive. That's pretty cool to hear. Kareeme Tucker (05:55): My biggest fish is a goldfish. I watch it in the tank, swim around. Yeah. Those get Derek Storms (06:00): Big. Those get big. Kareeme Tucker (06:02): They can get Derek Storms (06:02): Pretty big. Well, Misty, let's jump into some questioning here and just kind of learn the landscape of the money service business. From the MSB industry's perspective, how does state regulators fit into the overall supervisory framework for MSBs today? Misty Reeder (06:21): I mean, as far as the exam management perspective, the main thing that I see is that an examiner can come in and look at the company from an outside view and maybe see areas that we could use some improvement that just doesn't really stand out as much for us because a lot of times it's smaller things that can make a difference. So I think that is extremely helpful. Just that oversight and then the outside point of view, it really does help. Derek Storms (06:50): And then from MSBs that operate across multiple states, what role do you see individual state examinations playing in maintaining a strong compliance culture? Misty Reeder (07:03): I think it gives us different perspectives from different areas. I mean, because a lot of the regulations are different. Some of them are similar, especially with the model law, and that's what the model law was aimed to do. That really does help, but it does give us several different point of views and different areas in which we could improve. I think there's always areas where even companies or people can improve, and I think that it's very helpful to see those different point of views from the different states based on their different regulations. Derek Storms (07:34): Let's see if we can maybe talk about some of these issues or stresses or some of these areas a little bit. What are the top business issues or stresses that MSBs really are focused on right now? Misty Reeder (07:50): I would have to say potentially the different remittance taxes that are coming up right now. There's a few. I know there's a lot in discussion. So just balancing tracking those and working with various stakeholders within the company to make sure that we're compliant. I think that is a big topic right now, probably for most MSBs. Derek Storms (08:12): Money service businesses operate across many jurisdictions and often internationally. From your perspective, what does the state regulatory system look like from the industry side when you're navigating exams and investigations? Kareeme Tucker (08:28): Especially when you license across dozens of states. So from your perspective, essentially what we're saying, when regulators come in, you have the different state regulators that come in. What does it look like from your perspective when you have the various states coming in with the various jurisdictions? Or sometimes you may have people coming in because you operate internationally as well. From your perspective, what does a state examination system look like? Misty Reeder (08:55): So it does vary. It varies greatly between the US and other countries, even down to the way exams are handled, the way reports are handled. So you just have to get to know the examiners, have conversations with them frequently, and just make sure that we're all on the same page and how we manage things. But yeah, it definitely varies from the US. US is typically pretty standard across the board as far as the exam management process, but it is quite different from country to country when you're a global company. Kareeme Tucker (09:30): Well, Misty, that's really helpful context. And so let's shift into one of the biggest touchpoints between MSBs and regulators. And so we'll talk a little bit about state examinations and investigations, and I'd love to get your view on how they play out from the industry perspective. So you work with both state and federal regulators, so you see the full spectrum. And building on that experience, I'm curious what stands out to you during state exams specifically. Misty Reeder (09:58): So if I'm comparing the differences? Kareeme Tucker (10:03): Yeah. So when you look at and compare state examinations versus federal examinations, what stands out to you most when you're being examined between the two, particularly in terms of the focus, the communication, and the expectations? Misty Reeder (10:20): From my experience, federal examinations are a bit higher level, and the state examinations are more detailed reviews. Also, the scope is generally a lot broader for a federal exam. And states, obviously, the federal exam is just one set of federal regulations or various obviously. But when you're working with states, you're definitely focusing on the various requirements for those states and making sure that the documentation provided allows them to ensure that your company is in compliance with their regulations. Kareeme Tucker (10:57): So in terms of what's the most meaningful distinction in terms of their approach to do any examination? So it can be anywhere from the start of it, through the middle, through how it's concluded. Derek Storms (11:10): It also seems that federal regulators are not coming in quite as often. I just don't understand and trying to get maybe a little bit of a better understanding. Why is it that federal regulators seem to be, and I could be completely wrong here, it's just a longer period of time between examinations, and then obviously you have more states, so I would assume that that means you're going to have more state exams. But is there a coordination between the states and the federal regulators or are they just really independent and they're just on a longer timeframe? Misty Reeder (11:45): I think it really depends on the examiners. So a lot of times the approach is quite similar. When

they come on site, we can have times where all of the examiners will be on site, and then we'll have times where the state is typically on site, of course, outside of COVID. And so I think that makes a big difference. It makes a huge difference if the exam is on site. Because of my two federal exams, that one's a bit more challenging for me because we mostly have the state exams. Kareeme Tucker (12:16): Okay. Well, that's really where our primary focus is going to be about talking about how the impacts of state examinations. And so when exams go well, obviously they will surface things that ultimately we believe will strengthen operations. And so without naming any states or any specific exams, I'm just a little bit curious, have you seen examples where state examinations or investigations helped your organization identify risk early or led to meaningful operational improvements? Because we always look at it as there's always an opportunity to learn, always an opportunity to grow. And so when we come out and we examine companies, our goal is to ensure that we're partnering with the organizations with which we license and supervise. And we want to make sure that if we identify any deficiencies in any area, that we also give you all an opportunity to improve upon it. But also we hope that when we're conducting these examinations, if we've identified anything, that it allows for an opportunity for organizations to improve in various areas. (13:23): And so in this instance, I'm asking, have you seen where any examinations have helped your organization identify risk associated in some areas or if it has led to some meaningful operational improvements? Misty Reeder (13:39): I think with every exam, we see areas where we could improve in some areas. Yeah, I think every exam gives us that opportunity. Kareeme Tucker (13:48): And so like I stated, we're going to dig into the realities of MSBs that MSBs face day-to-day. We know that the industry moves really fast with real-time transactions, fraud risk, agent oversight, all things that are happening at once. There are a lot of operational pieces examiners don't always see behind the curtain. So with that being said, the MSB space faces unique operational challenges from real-time transactions to, like I said, to fraud prevention to agent oversight. What aspects of those realities do you wish examiners understood more deeply when they come on site or review your systems? Misty Reeder (14:28): I think, especially with a global company, one thing that is very important to realize is that we do have different partners across the globe that manage the different things like transaction monitoring and stuff like that. So that's a good thing to keep in mind, especially when it comes to timing and meetings and things like that. And then as far as the systems themselves, it's good for them to have a visual of the process to see that through. That's why I'm very for onsite exams because I think it gives the MSD

and the examiners time to really sit down, talk about things, explain things better, clear up any questions the examiners have, and then show them those systems and how they work. Kareeme Tucker (15:13): I think having boots on the ground, if you will, but having examiners in office and allowing examiners to view your processes, view your technology, view how you're using it, I think that's a great way to continue to have the flow of communication go back and forth by building those relationships so that there's clear understanding of what is being done, how it's being done, how it's being used, the effects of it, and things of that nature. And so I love that what you've stated in terms of wanting to see more onsite exams so that your regulators, your state regulators can have better insight as to how your business operates. Misty Reeder (15:55): I think it works better that way. I really do. I feel like the communication is better. Say you have a question. It's so much easier to just go into a conference room, have a quick conversation with somebody to clear up any questions that they have. Kareeme Tucker (16:08): That's a great tip that we want to ensure that our examiners are receiving from MSBs to know, don't be afraid, let's continue to have these conversations. We're having conversations, but let's continue to make sure that conversations are being had from both sides of the table. If there's something that when examiners come on site, we would also encourage that MSBs also say, "Hey, let us show you how this technology works. If you have any questions about it, let us walk you through what this technology looks like, what this looks like from our perspective as our agents are using or doing these processes. Let us show you what this looks like and how we operate from this capacity." And so with that being said, obviously technology is always ever-changing. And so can you share with us how technology is changing the ways that MSBs detect, manage, or escalate risk? (17:07): And how should regulators think about that evolution? Misty Reeder (17:10): I think especially, and this is not my area of expertise, but I think especially with a lot of the enhancements and with AI and the tools that can be used as far as risk management, transaction monitoring, I think that there's a lot put into that process. And like you said, it's ever-changing. So companies are making sure that they stay on top of things and make sure that everything is up-to-date. Kareeme Tucker (17:39): Well, you said that's not really your wheelhouse technology and things.That's not, Misty Reeder (17:43): Unfortunately. I wish I had the answer, but yeah, it's definitely not my area of expertise. Derek Storms (17:49): Let's switch to maybe a technology that I think we're all a little bit familiar with, and that's NMLS. How important is the consistency in how states use NMLS when supervising MSBs nationwide? Misty Reeder (18:07): It's extremely important, especially when

it comes to the reporting and the reporting that's entered into NMLS. If it's more consistent across the US, it enables the MSB to go in and submit the documents that are required. I think it avoids confusion on who requires what. That consistency helps significantly. Derek Storms (18:31): Definitely helps streamline the process from your perspective. And then even the regulator's perspective, they're able to get coordinated documents and information. MonGram uses NMLS and the SES for licensing and examinations. Which features of those systems really are the most helpful for you and your team? Misty Reeder (18:55): As far as the features in NMLS specifically? I think the ability to, because especially with exams, not all states use SES or some of them use the box. I think it gives MSBs a place to have one area where they can securely store the information and the communication flows well through SES. As far as NMLS, same thing really. It gives us a way to share information with examiners, provide updates before they're required. So we'll have a place to go in, make those changes, especially like an MU2 change. We're able to notify the states in one place of those changes. Derek Storms (19:44): And then specifically for NMLS, are there any capabilities that are the most valuable to MSBs or to MoneyGram in managing your nationwide compliance reports or filings or anything like that? Is there any capabilities that are the most valuable to you guys? Misty Reeder (20:06): As far as reporting, I would definitely say the call report. I think it is a way for us to report information for the various states in one area. So that is extremely helpful. Also, even down to the document uploads. I think that helps as well. Derek Storms (20:21): How about this? Where do you see the greatest opportunity for NMLS to better support effective state and industry engagement? Are there any opportunities that NMLS could improve in or something that you think would better help support the communication between the states and the industry? Misty Reeder (20:41): I think that with the working groups and the conferences, I think NMLS does a great job. So I think they definitely - Derek Storms (20:50): Well, we'd love to hear that. Thank you. Misty Reeder (20:52): And I think they're open to take feedback from the MSBs, share it with the examiners. I've had so many good experiences working with people at NMLS, down to just if I have a question, them reaching out to regulators. So I think NMLS does a great job. Derek Storms (21:10): Yeah. What I think I'm hearing is communication is the key thing. Absolutely. Misty Reeder (21:14): Absolutely. Derek Storms (21:14): Definitely during licensing and examinations, working groups, as long as we're communicating, we're building a better system for one another. We can help continue to drive that state industry engagement forward. Kareeme Tucker (21:29): What benefits do MSBs, or I'll say what benefits do you all see when states coordinate examinations or leverage examinations through the use of SES? Have you seen any big benefits when states use SES or to coordinate exams or to leverage exams? How does that feel from an industry perspective? Misty Reeder (21:51): I think the primary benefit of SES, for me personally, is the area to share that information securely. For the examiners to send those requests in one place, it minimizes the number of emails and it helps us. I feel like it helps us communicate better, but in a different way. I mean, naturally we'll always use emails if we have additional questions or follow-up, but I think it allows both the industry and the examiners get what they need in a timely manner and just have that one place to go to as opposed to sorting through your emails and trying to find something. Derek Storms (22:32): Yeah, let's follow up with that. Just from your perspective, the communication, should it all be in SES, in an MLS, or this fragmented where some's in emails and in different areas? It sounds like you really like that, the ability or features to be able to communicate all within the system. Is that accurate? Or describe to me what you guys prefer or what MoneyGram would prefer. Misty Reeder (23:01): I think the communication in SES is good, but sometimes it's a little more challenging to get the clarity that you need. And then in my opinion, I would prefer to jump on a call as opposed to going back and forth via email, because I think sometimes in email it can be a bit more confusing. Or if the person is not clear on the ask, there can be a lot of back and forth. So I'd rather jump on a call if I have questions outside of SES. But with my experience with the system, I think it works well for communication coordination and allows us to have that place to manage the exams and assign things to people. And again, that's opposed to emails. You can just assign something to someone in SES as opposed to sending out 50 emails. Kareeme Tucker (23:50): Oh, I agree. So I think we know the answer of this, but if you can make one enhancement to state coordination tomorrow, what would it be and why? Sounds like you're here, but I'll let you answer. The Misty Reeder (24:03): State coordination as far as the examiners? Kareeme Tucker (24:06): Yeah. When the states coordinate together and they do the multiple states together on an examination, if you can make an enhancement to that process, what would it be and why? Or at least what would it be? Misty Reeder (24:18): I think the main thing I would say is streamlining the questions that come through and just making sure that we have a primary point of contact. I think that is very helpful, even if it's one point of contact for each state. It is helpful and just helps with the timely turnaround, timely responses. But I've had great experience with that. Kareeme Tucker (24:45): Okay, that's great to hear. Misty Reeder (24:47): That is an important thing. Derek Storms (24:49): So

there's a big idea or push for multi-state reliance, networked supervision, leveraging each other's work. What value does the MSB industry see when states consider or leverage examination work completed by other states? How does that help you guys out? Misty Reeder (25:12): I think it helps significantly. It'll then allow us to further improve our program in between. It'll also, especially with a global company that has multiple regulators across the globe, it is very helpful when you've got international exams going on if another state accepts the previous exam report, especially if it hasn't been a year. Kareeme Tucker (25:35): Well, let's take a little step back. So stepping back to the national landscape for a moment, we're also watching some major federal developments like trust charters for MSBs and the new federal stablecoin under the Genius Act. The OCC recently provided conditional approval to several MSBs for trust company charters in addition to passing the Genius Act last year. Obviously Congress has created a new federal charter for issuers of stable coins. Misty, can you tell us long-term, what do you think this means for the state system of money transmission? Misty Reeder (26:10): For MoneyGram specifically, we plan on continuing to work with our state regulators. We find them really great partners, and that open communication really will help us make sure that we remain in compliance. Derek Storms (26:23): From your perspective, that partnership with the states, how can we continue to grow that partnership and that collaboration with one another? Is there anything that you would recommend or you'd like to see from the industry side or maybe even from the regulator side to continue to grow that partnership as some of these other things start coming in and these federal charters and that kind of stuff? How do we continue to strengthen that partnership between state regulators and the industry? Misty Reeder (26:54): I think just the open communication, receiving those communications, having conversations. I know me personally, I do get a lot of updates from our regulators. I have really great relationships with so many regulators. That communication makes a huge difference. Derek Storms (27:12): Yeah, definitely at the conferences and at the working groups, these are phenomenal ways to develop relationships and get to know one another. I think that also really helps develop that partnership and strengthen that partnership long-term for the state regulatory system. Let's move over to communication. What's the road ahead and what's trust look like in the industry? Looking ahead, what advice would you offer state regulators as they continue refining coordinated supervision and examination practices for the MSB industry? What advice would you offer regulators? Misty Reeder (27:54): As far as the coordination efforts? Kareeme Tucker (27:56): Yeah, we really want to just get your take on where the biggest shared opportunities are.

Misty Reeder (28:00): I think as far as the shared coordination between the states is just making sure that everybody is comfortable with the scope of the review and making sure that they're all on the same page, and then communicating that openly with the MSB. Kareeme Tucker (28:17): Okay. And so as you think about the next five years, what do you see as the biggest opportunities for states and MSBs to modernize supervision together? Misty Reeder (28:26): I think the model law. I think the model law does play a huge part in this. And I think that the more the states are accepting the model law, it definitely streamlines the process and makes everything a bit more collaborative. Derek Storms (28:40): Are you guys experiencing or seeing significant efficiencies or from the model law? Is that really helping out your operations as more and more states adopt the model law? Misty Reeder (28:53): I think so. As far as my team and our reporting, I think it does help when the states are all aligned on what they require. That's definitely helpful. Derek Storms (29:05): Yeah. You kind of mentioned call reporting, so I hadn't though of it from that perspective. So it definitely probably helps streamline the call report process with all states lining up on model law, correct? Misty Reeder (29:18): It does. Absolutely. Kareeme Tucker (29:19): Let's pivot a little bit. So what's something you think examiners would be surprised to learn about MSB operations? Because remember you talked earlier about coming in and if examiners can come on site and maybe get a tour or a look at your systems to see how you all operate, but what would be, let's say they were unable to, what would be something that they'd be surprised to learn about it? If they've never, let's say we have a new examiner and they've not yet gone on site to examine an MSB, what do you think they would be surprised to learn? Misty Reeder (29:52): I think, especially with a global company, they would be surprised to learn the various teams or departments or. Are not going to be on site during the exam. I think that surprises examiners sometimes. We definitely work around that with Teams meetings and things like that, but I think that's probably one of the bigger surprises when you do have a global team and we need to jump on a call with a team in Poland or wherever. Kareeme Tucker (30:18): Okay. And so if you could change one small thing about the state examination process that you feel would make the biggest impact, what would it be? Misty Reeder (30:28): I think that's a trick question. I'm kidding. Kareeme Tucker (30:31): No, no trick questions. No trick questions. Listen, every opportunity is an opportunity for improvement, right? Both sides. And so if there's something that can be a process that can be improved upon, listen, you've got free reign. Nothing is held against you. It's not a trick question. It's what does Misty believe would make the biggest impact? Misty Reeder (30:51): As

far as the examiner's improvement? Kareeme Tucker (30:53): In terms of the state examination process, the process overall from the time you're notified of an examination through the conclusion. If there's one small thing that you'd think that the process could change that would make a huge impact, what would it be? Misty Reeder (31:09): I think the scope of the review and considering. Take into consideration when the reporting is due, especially when it comes to, we'll say the MSB call report. I think the scope of the review is impacted by those reporting cycles. And so that would be the main thing is just take that into consideration. The end of the scope, especially the reporting cycles, when those are due, it's very helpful and gives both the MSB and the examiners kind of a clean cutoff date. Kareeme Tucker (31:38): So what I think I'm hearing is if when the scope period is identified that regulators take into consideration the due dates with which the call reports are due and to ensure that either it's aligned with it or that it's outside of that period to ensure that there are no issues when working through that particular exam for that scope period. I want to make sure I'm capturing what you're saying accurately, Misty. Misty Reeder (32:08): Yeah, I think it allows the company to provide all of the information that's available as opposed to waiting until later until information is available. Does that make sense? Derek Storms (32:22): I think that's all the questions. So we got some fun fishbowl questions. These are just kind of get to know you type things. So if you got a couple more minutes, we'll just kind of jump in. And these are quick, easy, one-word answers if that's all that you got here. All right, we want to know, we got to get to know you a little bit more. Coffee, tea, or energy drinks. What actually gets you through a long day? Misty Reeder (32:47): Coffee. Derek Storms (32:48): Coffee. Any special kind? Is it straight black or what do Misty Reeder (32:53): You do? So I really don't like the taste of coffee, so I usually get those bottled Starbucks Frappuccino drinks. Ooh, Kareeme Tucker (33:02): I like those Misty Reeder (33:02): Too. Derek Storms (33:03): Are you early mornings or late night? Which one is harder for you? Misty Reeder (33:08): Honestly, early mornings. However, I start my day at 5:00 AM. Derek Storms (33:12): So you'd rather stay up late and get up late, but - Misty Reeder (33:16): I am a night person, so I'm usually up late, up early. Derek Storms (33:20): I'm definitely the opposite. When I was in college, everybody made fun of me because I was in bed by 10 o'clock and they're all getting ready to go out. But when I'm an early bird, I like to get up early and get my day started. Kareeme Tucker (33:31): Yeah, get it over with. Do the hard parts early. Just be done. I'm with you on that. Misty Reeder (33:36): Before it gets hot, Kareeme Tucker (33:38): Especially - Right, right. Exactly. Well, I'm curious though, if you had to describe yourself as a compliance professional in three words, what would they be? Misty Reeder (33:47): As far as characteristics about Kareeme Tucker (33:49): Myself? Yeah, whatever it is. But describe yourself as whatever three words that first pop into your mind. Misty Reeder (33:56): Well, I'm very well organized. Kareeme Tucker (33:58): That's important for a compliance person, for sure. Misty Reeder (34:01): Very organized. I think a lot of people that work with me probably would say that I'm persistent with exam management, you have to be, and I am very focused. Kareeme Tucker (34:12): Sounds like a compliance person. Okay. Derek Storms (34:14): Absolutely compliance, 100%. Kareeme Tucker (34:17): 100%. So being that you've been in this role and in this area of expertise for quite some time, what would you say, what's one compliance professional pro tip that no one tells you, but everyone should know? Misty Reeder (34:30): I think that organization is the key. No one really tells you it, but you should know that. Just making sure that everything is organized, especially if you have to go back to it several years later, you want to make sure that you know where to find it. I get compliments quite often if I'm sharing my screen with somebody and trying to get through things about my organization. And I always tell them it's how I get things done because I know where to go, I know where to find things. So I hear about that quite often from my teammates. Kareeme Tucker (34:59): That's so good. That's so important, right? Tell us what you do, then show us that you do it and support it. Support it with your documentation. That is so crucial and so helpful. It makes the examination process go a little bit more seamlessly. And so Misty, we've had a lot of fun questions with you, but we cannot let you go without asking you our infamous pizza question that we like to ask all of our guests. We like to ask our guests, what's their favorite pizza place? If you could give us the name, the city and the state. And it could be anywhere. It could be anywhere in the world. It could be storeboard. It could be whatever you desire. If you like pizza, hopefully you like pizza. Misty Reeder (35:41): I do. I think most everybody likes pizza. In fact, Kareeme Tucker (35:44): That's what I say. When people say that they don't, I'm looking at them like, oh, oh, that's a little different if you don't like pizza, right? But what's your favorite pizza place? Misty Reeder (35:54): So it's not super fancy. There's a place where I live in Trenton, in Trenton, Texas. They have, which I never thought I would like, cauliflower pizza. And at first seems like that's just weird. How can you make a pizza healthy? But they make the best cauliflower pizza. I've had cauliflower pizza at other places. I'm like, I don't like that so much. But when I want cauliflower pizza, I'm going to go to them. It's called The Rock Yard. Kareeme Tucker (36:23): So now is it just a crust that's made out of cauliflower or is it like cauliflower pieces on top of the pizza? I need a visual on this. Misty Reeder (36:33): It's just the crust. Kareeme Tucker (36:34): Okay. Cause I know I've had that. I've had that. I don't know if I've had actual pieces of cauliflower on a pizza, but I've done the cauliflower crust and that's good. Misty Reeder (36:43): Yeah, I love it. It's really good. And I live in a small town, so there's really one place to eat literally, and that's the place. So I have to drive. If I want to go somewhere else, I have to drive about 25 minutes away. Kareeme Tucker (36:56): Oh, then yeah, I'm hungry by that point. And then I'm hungry again by the time I get back home. What's the name of the pizza place again? I got to make sure. Trenton, Texas. What's the name of it? Misty Reeder (37:05): It's called The Rock Yard. Kareeme Tucker (37:07): The Rockyard. Okay. You've heard it here. Misty Rita's favorite pizza place is The Rockyard. So if you all are ever in Trenton, Texas, you have to check out the cauliflower pizza at Rockyard. Okay. Well, listen, Misty, we have enjoyed you so much. Thank you so much for joining Derek and I on today's episode of In The Loop. We appreciate you giving us more insight and your willingness to talk to us about MoneyGram and the relationship between MoneyGram and the state regulators. We thank you so much for that. Derek, do you have anything else you'd like to add? Derek Storms (37:44): That is all, Misty. Thank you so much. We appreciate it. Thanks for joining In The Loop. We'll see you next time. Misty Reeder (37:52): Thank you. Derek Storms (37:54): Thanks for listening to In the Loop, brought to you by CSBS. Kareeme Tucker (37:58): If you want to connect with other examiners and learn more tips for the role and job, don't forget to follow us so you never miss an episode. Derek Storms (38:06): We'd love it if you'd spread the word by sharing our podcast with another examiner. Kareeme Tucker (38:10): See you next time. Derek Storms (38:17): Today's innovations are helping state agencies prepare for tomorrow. SES is a comprehensive technology platform that gives state agencies customized technology tools to conduct supervisory activities, including exams all in one place. With powerful collaboration tools, SES enables agencies to share information and conduct multi-state exams more efficiently, helping make network supervision a reality built by state agencies for state agencies. SES is transforming how exams get done. Ready to streamline your workflow? Visit csps.org to learn more.