Representative Engagements
Compliance Management System (CMS)
The unique relationships between an industrial bank and its strategic partners require the bank to maintain its own effective compliance management system (CMS), including a robust vendor management program comprising strong oversight of the operations and the CMS of its strategic partners. CrossCheck has completed reviews of the CMS of both sides of such relationships, ensuring that the bank’s CMS meets the requirements of its regulatory agency, while also tailoring the CMS reviews of the strategic partners to their individual operations using the bank’s overarching CMS guidance. These reviews include transaction testing of a judgmental sample of various loan products for compliance with applicable federal regulations. Products covered include private label credit cards, unsecured personal loans, and small business lending.
Client Type
Industrial Banks
Fintech
Service Type
Independent Compliance Review
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 two interdependent control components of an effective CMS which include:
- Board and Management Oversight; and
- Compliance Program, which includes:
- Policies and procedures;
- Training;
- Monitoring and/or audit; and
- Consumer complaint response
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 – Originator
Mortgage Banking – Servicer
Fintech
Service Type
Independent Compliance Review
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
Review of New Products and Services
A fintech company sought consulting services to assist them with a review of its home equity line of credit (“HELOC”) program documents by counsel licensed in 48 states. CrossCheck Compliance utilized its relationships with financial services law firms to source local counsel in each of the states with the expertise to perform the state specific reviews and managed the process including negotiating the services/fees of local counsel on behalf of the client, providing instructions for the reviews, responding to questions, tracking status, deliverables, and managing the invoicing/billing of the client. As a result of this engagement, the client was able to quickly and cost effectively roll out its HELOC program nationwide with a built-in network of legal counsel to support future needs.
Client Type
Fintech
Law Firm
Service Type
Compliance Consultation
