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Comprehensive Mortgage Compliance Services
CrossCheck provides independent compliance, internal audit, risk, and loan review services aligned to the full mortgage lifecycle.
Quality Control
Prefunding Quality Assurance
Detect defects, fraud indicators, and guideline exceptions before closing. Early review helps mortgage bankers 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 mortgage bankers 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 mortgage bankers strengthen oversight, improve consistency, and support regulator, investor, and insurer expectations.
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 mortgage compliance consulting services address these key program elements.
Mortgage 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 Originated Loan or Loan Servicing 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 mortgage company’s AML/CFT risk profile and the annual audit is required every 12-18 months, or when changes to its products/services occur.
Loan Review
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 mortgage bankers 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 mortgage bankers 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 clients make more informed valuation, negotiation, and integration decisions before closing.
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 mortgage lenders 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—helps mortgage lenders 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 our mortgage banker clients 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 mortgage companies that must comply with the CRA meet state 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 regulatory examinations. Explore Service
Community Credit Needs Assessment (CCNA)
A CCNA helps mortgage lenders 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
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 Program Review/Audit
CrossCheck conducts independent fair lending program reviews and audits to evaluate your organization’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 mortgage companies 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 analyze loan-level data and documentation to identify disparities or potential risks, helping mortgage bankers 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 company, including HMDA and 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 mortgage companies 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 mortgage 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 mortgage 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 mortgage lenders, servicers, and brokers include:
- Loan Operations
- Secondary Marketing
- Branch Operations
- Accounting
- 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.
Mortgage compliance audits we perform:
- Loan origination and loan servicing audits
- Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) audits
- Advertising and website audits
MERS Audit, Quality Assurance, & Reconciliation Services
CrossCheck performs the MERS® audit (Annual Report) due on December 31 that confirms the mortgage firm’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.
Litigation Support
File Review
CrossCheck has managed file reviews involving tens of thousands of loan files for mortgage lenders, servicers, and brokers. Our proven approach ensures efficient staffing, streamlined processes, and accurate results, helping you handle even the most complex projects with confidence.
Meet your Mortgage Team Experts
Mortgage Compliance and Loan Review FAQs
How can mortgage lenders assess the effectiveness of their compliance management system (CMS) across origination and servicing operations?
Mortgage lenders can evaluate CMS effectiveness by reviewing both the design and execution of compliance controls. This includes assessing board and management oversight, monitoring and testing programs, training initiatives, complaint response procedures, and adherence to policies and procedures. Independent assessments, such as those provided by CrossCheck, benchmark operations against regulatory guidance and industry best practices, helping lenders identify gaps, prioritize remediation, and strengthen control environments across origination and servicing.
How should mortgage companies evaluate loan portfolios for potential predatory or abusive lending risks?
Portfolio evaluations for predatory or abusive lending risks should integrate both quantitative and qualitative analyses. Key steps include reviewing underwriting decisions, documentation accuracy, fee structures, loan terms, borrower communications, and historical performance patterns. By comparing findings against regulatory expectations and industry norms, lenders can identify high-risk segments, understand root causes of potential issues, and implement corrective actions to mitigate liability and enhance operational integrity.
What role does independent review play in validating loan quality for investor reporting and securitization?
Independent reviews provide assurance that loan origination, underwriting, and servicing practices meet contractual, regulatory, and investor expectations. By benchmarking portfolio performance and compliance against established standards, CrossCheck helps lenders and servicers mitigate repurchase risk, enhance investor trust, and support confident securitization or investor reporting decisions.
What factors should senior management consider when evaluating the effectiveness of their fair lending or UDAAP audit programs?
Senior management should examine whether audit programs comprehensively cover both origination and servicing processes, incorporate risk-based sampling, and address demographic and geographic disparities. Program design should align with supervisory guidance, include clear escalation protocols, and produce actionable findings. CrossCheck’s approach emphasizes objective assessment of program scope, methodology, and results to ensure audits not only identify risks but also drive sustainable remediation and compliance improvements.
How can mortgage bankers optimize internal audit functions to detect compliance gaps while adding strategic operational value?
Optimizing internal audit functions requires integrating risk assessments, regulatory expectations, and operational priorities. Effective audits are risk-focused, include defined scope and methodology, and provide actionable recommendations beyond mere compliance findings. CrossCheck helps lenders align audit activities with business objectives, improve governance, and implement a structured plan that uncovers gaps, informs management decisions, and enhances overall control effectiveness.
What are key considerations when performing a look-back review of loan modifications under a regulatory MOU or settlement?
A look-back review should prioritize completeness, accuracy, and defensibility. This includes validating calculations, reviewing documentation and borrower communications, ensuring proper disclosure, and assessing adherence to the approved modification program. An objective approach, such as CrossCheck’s, combines statistical sampling, risk-based review, and thorough reporting to provide transparent findings that support regulatory compliance and timely remediation.
How can prefunding loan reviews help identify operational or underwriting gaps before they impact portfolio risk?
Prefunding loan reviews serve as a proactive risk management tool, allowing lenders to detect errors, guideline exceptions, or potential fraud before loans are closed. By assessing documentation completeness, underwriting consistency, and adherence to internal policies, these reviews reduce repurchase exposure, mitigate credit risk, and improve overall portfolio quality. CrossCheck’s approach ensures reviews are completed timely, accurately, and aligned with investor and regulatory expectations.
What best practices should mortgage lenders implement to ensure loan file integrity during portfolio acquisitions or mergers?
Loan file integrity during acquisitions requires a structured due diligence process that evaluates credit quality, regulatory compliance, and documentation completeness. Key practices include standardized file sampling, risk-focused assessments, reconciliation of loan-level data, and verification against investor or agency requirements. CrossCheck’s approach delivers objective analyses, identifies hidden risks, and provides actionable recommendations that support confident acquisition decisions and regulatory alignment.
What distinguishes CrossCheck’s team in mortgage compliance, loan review, and risk management?
CrossCheck brings deep, hands-on experience across the full spectrum of mortgage operations. Our team has worked with mortgage companies of all sizes – including originators, servicers, mortgage units of large banks, special servicers, warehouse lenders, and investors – providing insight across origination, underwriting, secondary marketing, securitization, due diligence, servicing, and operations. This extensive mortgage-specific expertise, combined with regulatory compliance, internal audit, fair lending, loan review, and litigation support capabilities, enables CrossCheck to deliver independent, actionable, and defensible guidance that sets us apart from other compliance partners.
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