• Filter by Client Type

  • Filter by Service Type

Representative Engagements

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 approved loan workout were calculated and disclosed properly to the borrower. Detailed reporting, including identifying refunds to affected borrowers, was provided to the CFPB. As a result, the client was able to meet the CFPB’s requirements in a timely manner.

Client Type

Mortgage Banking – Servicer

Service Type

Compliance Consultation – Issue Remediation


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 prior to the exam thereby improving their compliance management system and reducing the potential for regulatory criticism.

Client Type

Mortgage Banking – Originator

Mortgage Banking – Servicer

Service Type

Compliance Consultation


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


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 the governance and internal controls within the organization.

Client Type

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

Service Type

Compliance Consultation


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 procedures, and foreclosure processing. These reviews have kept the clients in compliance with regulatory requirements and allowed the clients to improve their operational controls.

Client Type

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

Mortgage Banking – Servicer

Service Type

Loss Mitigation


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


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 developing the methodology to complete the review, trained the review team, provided management reporting, and maintained quality assurance throughout the project. Detailed analysis of each customer’s activity and loan servicing was performed over the life of the loan to identify situations that resulted in customer harm. Recommendations for customer remediation were provided to management. We also provided management with the information it needed to evaluate its practices, and take appropriate corrective action to mitigate any future risk and the potential for consumer harm.

Client Type

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

Service Type

Compliance Consultation – Issue Remediation