Your CMS must contain, at a minimum, the following functionalities:

(1) Board and management oversight; and

(2) Compliance program, which includes:

(a) Policies and procedures;

(b) Training;

(c) Monitoring and/or audit; and

(d) Consumer complaint response.

For the details of each component, see the Supervision and Examination Manual from the Consumer Financial Protection Bureau (CFPB) at the following link: https://www.consumerfinance.gov/policy-compliance/guidance/supervision-examinations/. The CMS-specific procedures can be used by an entity to self-assess the effectiveness of its CMS.

Your CMS must be maintained as part of your books and records.