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Compliance, Risk, and Audit Support for Consumer Finance Lenders
We help consumer finance organizations meet federal and state regulatory expectations while strengthening compliance management system (CMS) effectiveness and managing fair lending and consumer complaint risk.
Regulatory Compliance
Compliance Management System (CMS) Consulting Services
Management and the board of directors have ultimate responsibility for compliance oversight. Ensuring the effectiveness and sustainability of the regulatory compliance management system (CMS) through essential program elements from policies and procedures to consumer complaints is key to that oversight. CrossCheck’s consumer finance compliance consulting services address these key program elements.
Consumer finance compliance services:
- Compliance Policy & Procedure Review/Development – Establish and incorporate compliance requirements and responsibilities into business processes.
- Compliance Risk Assessment – Identify and risk-rate compliance risks and controls for a refined focus.
- Monitoring, Audit, or Targeted Loan or Deposit Compliance Reviews – Review the operations and compliance with regulatory requirements to ensure responsibilities are carried out, legal requirements met, corrective action taken, and procedure and systems updates are made.
- Training – Communicate compliance responsibilities and guidance to all employees, management, and the board.
- Compliance Investigations & Remediation – Research and understand the root cause of identified issues and the persons impacted to ensure the corrective action and remediation addresses the issue and not the symptoms.
- Consumer Complaint Handling – Establish procedures to categorize, risk-rate, escalate, and address the root causes of consumer complaints. Ensure corrective actions are taken to prevent complaints from recurring.
Anti-Money Laundering/Combatting the Financing of Terrorism (AML/CFT) Services
CrossCheck consultants perform annual AML/CFT audits and risk assessments required by the FFIEC, prudential, and state regulators. An assessment of a consumer finance company’s AML/CFT risk profile and the annual audit is required every 12-18 months, or when changes to its products/services occur.
Fair Lending
Fair Lending Statistical Analysis
Our fair lending statistical analysis offerings identify potential disparities across pricing, underwriting, exceptions, and redlining risk. We apply advanced modeling and regulatory insight to uncover patterns of lending activity that could point to potential disparate treatment, helping consumer finance companies mitigate risk, demonstrate compliance, and strengthen fair lending controls with defensible, data-driven results. Explore Service
Fair Lending AI Model Output Testing
Conducting statistical testing at each stage of the credit decision funnel—output, configuration, manual review, and final decisioning—enables consumer finance companies to identify whether disparities are associated with the AI model itself, its implementation, or later manual decisions. As AI adds complexity to credit decisioning, CrossCheck’s proprietary AI Fair Lending Funnel Analysis℠ helps isolate and assess risk at each stage. Explore Service
Fair Lending Program Review/Audit
CrossCheck conducts independent fair lending program reviews and audits to evaluate your company’s policy effectiveness, governance, and monitoring systems. Our experts assess program design against regulatory expectations, identify control gaps, and provide actionable recommendations to enhance compliance readiness and examiner confidence.
Fair Lending Risk Assessment
CrossCheck’s fair lending risk assessments evaluate products, policies, and practices to identify potential disparities or gaps in compliance management. We deliver prioritized, actionable findings that help consumer finance lenders proactively address examiner expectations, strengthen oversight, and maintain a fair and inclusive lending environment.
Fair Lending Program Development
CrossCheck designs and enhances fair lending compliance management systems that align with regulatory expectations and institutional goals. Our approach integrates governance, monitoring, training, and data analytics, creating a sustainable framework that proactively manages fair lending risk and supports continuous compliance improvement.
Fair Lending File Reviews
CrossCheck’s fair lending file reviews provide granular insight into pricing, underwriting, and exception practices. We geocode, proxy, and analyze loan-level data and documentation to identify disparities or potential risks, helping consumer finance lenders validate decision processes and demonstrate fair, consistent treatment of all applicants.
Fair Lending Training
CrossCheck’s fair lending compliance training programs equip board members, management, and staff with practical knowledge of regulatory requirements across all areas of fair lending and emerging risks at your company. We tailor content to your institution’s products and risk profile, fostering a culture of compliance and accountability across all levels of the organization.
Fair Lending Remediation and Issue Resolution
CrossCheck assists consumer finance lenders in addressing and resolving identified fair lending issues through targeted remediation strategies. Our experts develop corrective action plans, strengthen controls, and engage effectively with regulators to restore compliance, enhance governance, and minimize reputational and operational risk.
Internal Audit
Internal Audit Risk Assessment & Audit Plan Development
Identification and prioritization of risks allows your consumer finance company to focus on areas most important to meeting your business goals. An objective assessment of the likelihood and impact of financial, operational, and compliance risk and mitigating controls help drive the focal points of your internal audit plan.
Operational Audits
Control design and effectiveness and risk management processes are imperative for well-controlled finance companies. Review of policies and procedures, key personnel interviews, and testing will determine the completeness and effectiveness of existing controls in mitigating risks inherent in daily execution of activities. Recommendations address root causes to prevent recurrence.
Auditable areas for consumer finance companies include:
- Deposit and Loan Operations
- Secondary Marketing
- Branch Operations
- Accounting
- Asset Liability Management
- Funds Management – Investments
- Payroll/Human Resources
- Wire Transfer
- Third-Party/Vendor Management
- Mortgage Electronic Registration Systems (MERS) Audits
Compliance Audits
An independent compliance audit will assess whether your compliance management system (CMS) is operating as intended and maximizes compliance performance. In addition to a full review of the CMS and regulations applicable to a client’s products and services, CrossCheck performs targeted compliance reviews across key regulatory areas.
Consumer finance audits we perform:
- Consumer deposit and lending regulations
- Consumer loan products and services
- Loan origination and loan servicing regulations
- Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulations
- Advertising and website regulations
Meet Your Consumer Finance Experts
Consumer Finance Compliance FAQs
Which federal and state regulations does CrossCheck commonly support?
CrossCheck supports a broad range of federal and state regulatory requirements applicable to consumer finance organizations. This includes oversight by the CFPB, FTC, and state regulators, as well as compliance with fair lending, UDAAP, FCRA, ECOA, Regulation E, TILA/RESPA, and servicing requirements. Engagements are tailored to the organization’s products, business model, and regulatory footprint.
How does CrossCheck help clients improve their compliance management systems (CMS)?
CrossCheck helps clients strengthen their compliance management systems by assessing and enhancing core CMS components, including governance and oversight, policies and procedures, training, monitoring and testing, consumer complaint management, and issue management. Support may include gap assessments, program design recommendations, and practical guidance aligned with regulatory expectations.
Does CrossCheck conduct fair lending risk assessments and program reviews?
Yes. CrossCheck conducts fair lending risk assessments and program reviews using a risk-based approach. Services may include risk scoping, coordination of data analysis, reviews of policies, procedures, and controls, and evaluation of governance and oversight. CrossCheck also supports remediation planning to address identified risks and strengthen fair lending programs.
How does CrossCheck support internal audit and independent compliance reviews?
CrossCheck provides support across second-line and third-line functions by conducting independent compliance reviews, targeted testing, and internal audit support. Reviews are designed to be objective and well-documented, with clear findings and board-ready reporting that supports management response and regulatory review.
Does CrossCheck assist with regulatory remediation and corrective action plans?
Yes. CrossCheck assists clients with regulatory remediation by validating issues, developing corrective action plans, and supporting execution and ongoing tracking. The focus is on helping organizations address root causes, meet regulatory expectations, and demonstrate sustainable program improvements.
What experience does CrossCheck bring to consumer finance compliance engagements?
CrossCheck’s team includes former regulators, compliance officers, and industry practitioners with hands-on experience across consumer lending and servicing. This background enables CrossCheck to provide practical, regulator-aligned insight informed by both supervisory expectations and operational realities.
How does CrossCheck work with in-house compliance, legal, and audit teams?
CrossCheck works collaboratively with in-house compliance, legal, and audit teams through a delivery model designed to complement existing resources. Engagements are structured to integrate with internal processes, avoid duplication, and provide independent insight while supporting management and governance objectives.
What types of consumer finance companies does CrossCheck support?
CrossCheck works with a wide range of consumer finance organizations, including nonbank lenders, mortgage companies, auto finance companies, fintechs, and servicing organizations. Engagements are tailored based on product offerings, regulatory oversight, and operational complexity, with a focus on helping clients meet federal and state compliance requirements and manage risk effectively.
Representative Engagements
