We were engaged by a regional bank to review a sample of loans from three proposed separate bulk whole loan purchases. The bank requested we determine whether the portfolios which were predominately conventional and jumbo loans, were originated in compliance with regulatory requirements. All disclosures required by Regulation Z- Truth-in-Lending and Regulation X – Real… Read more »
Review of New Products and Services
A fintech company sought consulting services to assist them with a review of its home equity line of credit (“HELOC”) program documents by counsel licensed in 48 states. CrossCheck Compliance utilized its relationships with financial services law firms to source local counsel in each of the states with the expertise to perform the state specific… Read more »
Telephone Consumer Protection Act (TCPA) and Fair Debt Collection Practices Act (FDCPA)
Due to the growth of class action TCPA litigation and settlements, the client engaged CrossCheck to perform a targeted review of its debt collection practices with a focus on compliance with TCPA requirements. Our engagement covered the client’s practices as well as the client’s third-party loan servicer and collection agents and included a review of… Read more »
Website Compliance Review
Continued growth and the ensuing regulatory scrutiny led a large credit union to request a compliance review of its extensive website. CrossCheck focused the review on the advertising provisions of all applicable regulations, including those specific to credit unions, as well as potential UDAAP pitfalls. The review encompassed all pages and all links on the… Read more »
Compliance Management System (CMS)
The unique relationships between an industrial bank and its strategic partners require the bank to maintain its own effective compliance management system (CMS), including a robust vendor management program comprising strong oversight of the operations and the CMS of its strategic partners. CrossCheck has completed reviews of the CMS of both sides of such relationships,… Read more »
Auto Finance Review
Review of the auto finance program covering the various elements of the auto loan life cycle, including origination and servicing processes. Such reviews include assessment of the quality of the credit union’s CMS for detecting and preventing violations of Federal regulations applicable to auto loan origination or servicing and identification of credit union practices that… Read more »
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) and Debt Protection Products
Due to regulatory concerns related to UDAAP compliance, the bank requested CrossCheck assist with a multi-phased review of its administration of debt protection products including a look-back of thousands of customer loans with debt protection originated over several years. We provided a project manager and a team of a dozen consultants.The project manager assisted in… Read more »
Foreclosure Management Look-Backs
CrossCheck has executed numerous default management and foreclosure reviews. The objectives for these reviews aligned with the lookback requirements outlined in the Consent Orders issued to the 14 largest loan servicers in 2011. Each review included the requirements set forth by the CFPB related to early Intervention with delinquent borrowers, continuity of contact, loss mitigation… Read more »
Compliance Policy and Procedures Development
As the regulatory environment and the requirements imposed on financial institutions continue to evolve, CrossCheck has been engaged by a variety of mortgage entities and community banks to review and enhance compliance related policies and procedures. This has also included the development of required policies that previously did not exist, enabling the client to strengthen… Read more »
Compliance Management Systems (CMS)
As non-depository mortgage entities and fintechs align their internal control structures with the expectations of the CFPB, numerous clients have engaged CrossCheck to perform compliance management system (CMS) assessments of the two interdependent control components of an effective CMS which include: Board and Management Oversight; and Compliance Program, which includes: Policies and procedures; Training; Monitoring… Read more »
Training
Clients taking a proactive approach or responding to regulatory finding have engaged CrossCheck to prepare and conduct a variety of training sessions for business lines, senior management, and board committees. Training topics included Home Mortgage Disclosure Act; Community Reinvestment Act requirements; Bank Secrecy/Anti-Money Laundering, and loan servicing rules. As a result of the training, clients… Read more »
CFPB MOU Remediation
After receiving a memorandum of understanding (MOU) from the CFPB, one of the largest independent mortgage originator/servicers engaged CrossCheck – upon CFPB non-objection – to conduct a look-back of several thousand loan modifications made over a two-year period. We reviewed each modification to determine if fees assessed and cash contributions granted as part of the… Read more »
CFPB Readiness Exams
With implementation of the Dodd-Frank Act, mortgage companies became subject to examination by the Consumer Financial Protection Bureau (CFPB). Mortgage originators and servicers alike have engaged CrossCheck to assess their readiness for these examinations. Our approach for the review is based on the CFPB examination guidance and our findings enabled the originator/servicer to remediate issues… Read more »
