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Supporting Credit Unions With Compliance, Risk, and Audit Needs
CrossCheck helps management and boards meet NCUA expectations, strengthen compliance programs, and manage risk across lending, operations, and enterprise risk management.
Regulatory Compliance
Compliance Management System (CMS) Consulting Services
A credit union’s management and the board of directors have ultimate responsibility for compliance oversight. Ensuring the effectiveness and sustainability of an NCUA-aligned CMS through essential program elements from policies and procedures to consumer complaints is key to that oversight. CrossCheck’s compliance consulting services address these key program elements.
Regulatory compliance consulting 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, and Targeted Loan or Deposit Compliance Reviews – Review the credit union’s 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 credit union 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, the NCUA, and state regulators. An assessment of a credit union’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 credit unions 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 credit unions 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 credit unions isolate and assess risk at each stage. Explore Service
HMDA Compliance Services
CrossCheck performs detailed systemic and manual HMDA data integrity reviews to ensure accuracy, completeness, and consistency in your loan application registers (LAR). From source documentation and data mapping to sample or full-LAR scrub to LAR preparation and submission, our experts identify reporting gaps and data quality issues before submission, reducing examination findings and supporting credible analytics for fair lending and CRA performance evaluation. Explore Service
Community Reinvestment Act (CRA) Services
CrossCheck’s CRA services help credit unions in applicable states develop and execute strategies that meet regulatory expectations and community needs. We assess performance context, identify opportunities, and optimize CRA programs to demonstrate meaningful community impact while mitigating compliance risk during state regulatory examinations. Explore Service
Community Credit Needs Assessment (CCNA)
A CCNA helps credit unions assess community credit needs, identify gaps in access, and support financial inclusion within specific market areas. By proactively evaluating and addressing community needs, lenders can enhance access to credit and financial inclusion while meeting regulatory obligations. CrossCheck has extensive experience in providing tailored CCNAs that provide data-driven insights into local lending patterns, economic trends, and community demographics. Explore Service
Fair Lending Program Review/Audit
CrossCheck conducts independent fair lending program reviews and audits to evaluate your institution’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 institutions 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.
Section 1071 Small Business Data Integrity Reviews
CrossCheck performs Section 1071 business data integrity reviews to ensure accurate small business lending data collection and reporting. Our experts verify processes, detect inconsistencies, and enhance governance frameworks, helping institutions prepare for CFPB compliance expectations and future fair lending analyses. Explore Service
Fair Lending File Reviews
CrossCheck’s fair lending file reviews provide granular insight into pricing, underwriting, and exception practices. We analyze loan-level data and documentation to identify disparities or potential risks, helping credit unions 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 at your credit union, including HMDA, CRA, and emerging risks. 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 credit unions 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 credit union 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 credit unions. 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 credit unions include (but not limited to):
- 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 credit union’s 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.
Credit union regulatory compliance audits we perform:
- Consumer deposit and lending regulations
- Consumer deposit products and services
- Loan origination and loan servicing regulations including Truth in Lending Act (TILA) /Real Estate Settlement Procedures Act (RESPA) integrated disclosures (TRID) compliance
- Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulations
- Advertising and website regulations
MERS Audit, Quality Assurance, & Reconciliation Services
For credit unions registered with MERS®, CrossCheck performs the MERS® audit (Annual Report) due on December 31 that confirms the member’s processes and controls are in place, ensuring compliance with MERS® requirements. In addition, CrossCheck can also perform loan servicing system data reconciliations to MERS® system data and required quality assurance reviews.
Loan Review
Commercial Loan Review Services (Member Business Loan Review)
Our commercial loan review experts provide an independent assessment of the credit union’s commercial loan portfolio to evaluate the quality of underwriting, credit administration, and risk management practices; validate the accuracy of assigned risk ratings; identify emerging credit risks that may affect the collectability of the portfolio; and provide actionable recommendations that assist management and the board in maintaining a safe, sound, and well-managed commercial lending program.
Residential Mortgage Loan Review Services
CrossCheck performs residential mortgage loan review to assess credit quality, documentation, underwriting consistency, and identify compliance issues that can affect salability, repurchase risk, and portfolio performance. Our reviews help credit unions identify file-level defects and recurring exceptions before they create broader exposure.
Loan Portfolio Review
CrossCheck conducts targeted portfolio reviews for correspondent lending, acquired loans, legacy assets, purchased portfolios, and higher-risk segments. We help credit unions evaluate broader portfolio trends, concentrations, and hidden risk beyond individual file exceptions.
M&A Due Diligence Support
For mergers, acquisitions, and balance sheet transfers, CrossCheck provides independent loan review and due diligence focused on underwriting quality, transaction risk, compliance concerns, and portfolio fit. Our work helps credit unions make more informed valuation, negotiation, and integration decisions before closing.
Quality Control
Prefunding Quality Assurance
Detect defects, fraud indicators, and guideline exceptions before closing. Early review helps credit unions reduce downstream losses, support sound credit decisions, and prevent issues that can lead to repurchase exposure or borrower harm.
Post-Closing Quality Control
Validate underwriting, documentation, and compliance execution after closing through independent file review. Our post-closing QC helps credit unions uncover defects, measure trends, and improve overall loan quality, while meeting all Fannie Mae, Freddie Mac, FHA, VA, and USDA requirements.
Servicing Quality Control
Assess servicing execution, documentation, and control effectiveness to identify borrower-impact risk, compliance gaps, and recurring issues in ongoing loan administration. Our servicing QC helps credit unions strengthen oversight, improve consistency, and support regulator, investor, and insurer expectations.
Meet your Credit Union Compliance Experts
Credit Union Compliance FAQs
How do you ensure your compliance assessments align with NCUA and state examiner expectations?
CrossCheck designs compliance assessments based on current NCUA guidance, state supervisory priorities, and examination practices observed across the credit union industry. Our consultants apply examiner-informed judgment to focus reviews on areas that receive heightened regulatory attention. Results are framed using clear, supportable documentation that aligns with how regulators evaluate compliance programs during examinations.
What is CrossCheck’s approach to evaluating the effectiveness of a credit union’s compliance management system (CMS)?
CrossCheck assesses CMS effectiveness by evaluating how well program components function together in practice, not just on paper. Reviews examine oversight, policy governance, training effectiveness, monitoring and testing results, complaint handling, and issue resolution. Emphasis is placed on scalability, consistency, and whether the CMS supports ongoing compliance as products, services, and risks evolve.
How does CrossCheck support internal audit functions without duplicating management or audit responsibilities?
CrossCheck provides independent support that enhances internal audit coverage without performing management activities or overlapping existing audit work. Our engagements are structured to supplement internal capabilities, address targeted risk areas, and provide objective insight that internal audit teams can rely on while maintaining appropriate role separation across the lines of defense.
How do you help credit unions prepare for NCUA and state regulatory exams?
CrossCheck supports exam preparedness by helping credit unions assess readiness, confirm control effectiveness, and identify potential regulatory concerns before examinations begin. This may include targeted reviews, documentation validation, and guidance on responding to examiner inquiries. The focus is on reducing surprises and ensuring management is prepared to address examiner focus areas confidently.
What level of board and committee reporting does CrossCheck provide to credit unions?
CrossCheck delivers reporting tailored to board and committee oversight responsibilities, emphasizing key risks, themes, and management considerations rather than operational detail. Deliverables are designed to support informed governance discussions and regulatory expectations for board awareness. When appropriate, CrossCheck presents findings directly to governance bodies.
How do you evaluate third-party and vendor-related compliance risk for credit unions?
CrossCheck evaluates third-party compliance risk by reviewing governance structures, vendor selection and due diligence processes, contractual requirements, and ongoing oversight activities. The assessment considers how third-party relationships impact regulatory compliance, member experience, and operational resilience, consistent with NCUA expectations for vendor risk management.
How does CrossCheck maintain independence while working collaboratively with management and boards?
CrossCheck maintains objectivity by establishing clear engagement boundaries and delivering conclusions grounded in evidence and regulatory standards. While we work closely with management and boards to understand operations and context, our findings and recommendations remain independent and defensible, supporting both governance needs and regulatory scrutiny.
How does CrossCheck coordinate with internal teams (compliance, legal, risk, audit)?
CrossCheck works closely with in-house compliance, legal, risk, and audit teams to fit seamlessly into existing processes. We take the time to understand how your teams operate, clarify roles upfront, and focus our work where it adds the most value. The goal is a collaborative, low-friction engagement that provides independent insight without creating extra work or duplicating effort.
Does CrossCheck provide credit unions with quality control services?
CrossCheck provides prefunding and post-closing quality control services that meet agency and regulatory requirements. Our customized audits focus on identifying defects and root causes which allow your lending operations to make effective policy changes, recognize training opportunities, and mitigate credit and compliance risk.
Representative Engagements
