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Representative Engagements

Anti-Money Laundering/Bank Secrecy Act

CrossCheck performs Anti-Money Laundering/Bank Secrecy Act independent audits for the various client segments it serves. Our approach is based on the examination guidelines published by the Federal Financial Institutions Examination Council (FFIEC) and FinCEN requirements. An independent audit provides management with an unbiased assessment of compliance with the anti-money laundering requirements and raises the state of regulatory compliance within the institution. The recommendations we provide help improve operational and compliance controls.

Client Type

Mortgage Banking – Originator

Mortgage Banking – Servicer

Intermediate Banks ($1 – $10 billion in assets)

Community Banks (<$1 billion in assets)

 

Service Type

Independent Audit


Audit Co-Source

Continued growth and increased regulatory scrutiny prompted a client to have CrossCheck assist them with the implementation of an internal audit function. After developing an audit charter, performing an audit risk assessment, and providing a multi-year internal audit plan, we assigned experienced internal audit consultants to complete the audit plan. The goal of an internal audit is to identify areas for improvement in the institution’s control environment, policies, procedures and practices, and to provide practical, sustainable recommendations that address the root cause of issues identified. Each internal audit consultant assigned to the engagement was equipped with the knowledge and experience needed to fully understand the functional area being audited and make value added recommendations. In addition to completing the audit plan each year, we regularly provide reports to the Audit Committee of the Board of Directors, and provide ongoing consultation to the institution as needed.

Client Type

Mortgage Banking – Originator

Mortgage Banking – Servicer

Intermediate Banks – ($1 – $10 billion in assets)

Community Banks (<$1 billion in assets)

Credit Unions

Service Type

Audit Function Development


California Department of Business Oversight (DBO) Per Diem Interest Audit

The California Department of Business Oversight (DBO) alleged a large mortgage lender had not properly computed per diem interest on California loan closings. The lender engaged us to perform an audit of a sample of loans selected by the DBO and recomputed per diem interest. We found, and documented in a report, the lender’s proper compliance resulting in dismissal of the DBO action and avoidance of significant fines.

Client Type

Mortgage Company

Law Firms

Service Type

Compliance Audit


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


Mortgage Electronic Registration Systems, Inc. (MERS®) Independent Audit

Mortgage servicers with more than 1,000 loans registered with MERS® are required to have an independent third party monitor their performance against their quality assurance plans. We have performed this role for a number of servicers, providing both the servicer and MERS® with an unbiased evaluation of the servicer’s procedures for complying with MERS® rules and requirements. Additionally, in anticipation of meeting the 1,000 registered loan threshold, CrossCheck has assisted other servicers in developing and implementing the procedures needed to successfully meet the MERS® annual requirements.

Client Type

Mortgage Banking – Servicer

Service Type

Operational Audit


Mortgage Operations Audit

The client requested CrossCheck perform an assessment of its mortgage and home equity operations. The scope and objective of this review included an assessment of compliance with applicable consumer and safety and soundness regulations, evaluation of internal controls, determination of adherence to and effectiveness of the bank’s policies and procedures, and comparison to industry standards and best practices. This independent review provided the client with an unbiased evaluation to strengthen its operations and reduce its overall risk exposure.

 

Client Type

Regional Bank ($10 – $50 billion in assets)

Service Type

Compliance Audit
Operational Audit


Truth in Lending and RESPA Integrated Disclosure (TRID) Compliance Monitoring

With all the challenges and nuances of the new Know Before You Owe (TRID) rules, management requested CrossCheck perform quarterly monitoring of its compliance with the TRID requirements. We established a quarterly process to select and review a sample of the bank’s new loan production, stratifying the sample for higher risk issues and out of tolerance situations that could result in expensive customer reimbursements. We identified the root causes of many of the issues, and recommended operational enhancements to reduce recurrence of errors. Management used the trending analysis reports we provided to track progress over time, and was able to make the operational changes it needed to address compliance going forward.

Client Type

Regional Bank ($1 – $10 billion in assets)

Service Type

Compliance Audit