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Representative Engagements

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 four pillars of an effective CMS which include:

  • Corporate governance and oversight of the compliance function
  • Compliance program (policies and procedures; compliance training and ongoing compliance monitoring)
  • Consumer complaint response process
  • Independent audit of compliance

Our approach is based on the CFPB supervisory guidance and industry best practices. Our findings assist the client in strengthening the pillars for a more robust, fully operational and sustainable CMS.

Client Type

Mortgage Banking – Originators

Mortgage Banking – Servicers

Fintechs

Service Type

Independent Compliance Reviews


Internal Audit Plan Development and Risk Assessment

Continued growth and increased regulatory and investor scrutiny have prompted a number of mid-size, private non-depository mortgage servicers, originators, and fintech companies to implement an internal audit function. CrossCheck deploys experienced and certified internal auditors to assist with development of an internal audit plan including a risk assessment, audit schedule, and management and board reporting. CrossCheck also executes the plan and provides consultation to the institution as needed on a full out-sourced or co-sourced partner arrangement. As a result, clients have an understanding of the key operational and compliance risks in their company and are successful in meeting investor (e.g. Fannie Mae MORA), state, and CFPB requirements.

Client Type

Mortgage Banking – Originator

Mortgage Banking – Servicer

Fintech

Service Type

Audit Function Development


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 have enhanced internal training curriculums and procedural documentation.

Client Type

Mortgage Banking – Originator
Mortgage Banking – Servicer
Community Banks (<$1 billion in assets)

Service Type

Compliance Consultation