Representative Engagements
Audit Co-Source
Continued growth and increased regulatory scrutiny prompted a client to have CrossCheck assist them with the implementation of an internal audit function. After developing an audit charter, performing an audit risk assessment, and providing a multi-year internal audit plan, we assigned experienced internal audit consultants to complete the audit plan. The goal of an internal audit is to identify areas for improvement in the institution’s control environment, policies, procedures and practices, and to provide practical, sustainable recommendations that address the root cause of issues identified. Each internal audit consultant assigned to the engagement was equipped with the knowledge and experience needed to fully understand the functional area being audited and make value added recommendations. In addition to completing the audit plan each year, we regularly provide reports to the Audit Committee of the Board of Directors, and provide ongoing consultation to the institution as needed.
Client Type
Intermediate Bank – ($1 – $10 billion in assets)
Community Bank (<$1 billion in assets)
Credit Union
Mortgage Banking – Originator
Mortgage Banking – Servicer
Service Type
Audit Function Development
Auto Finance Review
Review of the auto finance program covering the various elements of the auto loan life cycle, including origination and servicing processes. Such reviews include assessment of the quality of the credit union’s CMS for detecting and preventing violations of Federal regulations applicable to auto loan origination or servicing and identification of credit union practices that increase the risk of harm to consumers. CrossCheck’s reviews incorporate the CFPB’s examination procedures covering the following modules:
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- Credit Union Business Model
- CMS
- Advertising and Marketing
- Application and Origination
- Payment Processing, Account Maintenance, and Optional Products
- Collections, Debt Restructuring, Repossessions, and Accounts in Bankruptcy
- Customer Complaints and Inquiries
- Credit Reporting, Information Sharing, and Privacy
Client Type
Credit Union
Service Type
Independent Compliance Review
Bank Secrecy Act/Anti-Money Laundering
CrossCheck performs Bank Secrecy Act/Anti-Money Laundering independent audits for the various client segments it serves. Our approach is based on the examination guidelines published by the Federal Financial Institutions Examination Council (FFIEC) and FinCEN requirements. An independent audit provides management with an unbiased assessment of compliance with the anti-money laundering requirements and raises the state of regulatory compliance within the institution. The recommendations we provide help improve operational and compliance controls.
Client Type
Regional Bank ($10 – $50 billion in assets)
Intermediate Bank ($1 – $10 billion in assets)
Community Bank (<$1 billion in assets)
Mortgage Banking – Originator
Mortgage Banking – Servicer
Consumer Finance
Service Type
Independent Audit
Loan and Credit Risk Process Review
A credit union experiencing rapid growth of its member business loan portfolio requested an independent review of its business loan portfolio and related loan policies and procedures to ensure adherence to safety and soundness expectations. While overall policies and procedures were satisfactory, recommendations were made to enhance loan review procedures and compliance with the Flood Disaster Protection Act and implementing regulations. Our review facilitated a stronger business loan risk management process and attendant flood compliance procedures to help avoid potential monetary penalties.
Client Type
Credit Union ($1 – $10 billion in assets)
Service Type
Member Business Loan Review and Policy and Procedures Review
Telephone Consumer Protection Act (TCPA) and Fair Debt Collection Practices Act (FDCPA)
Due to the growth of class action TCPA litigation and settlements, the client engaged CrossCheck to perform a targeted review of its debt collection practices with a focus on compliance with TCPA requirements. Our engagement covered the client’s practices as well as the client’s third-party loan servicer and collection agents and included a review of policies and procedures related to FDCPA and TCPA, the client’s internal monitoring of its own collectors as well as the third parties, and specific transaction testing. The transaction testing focused on both written communication (collections letters and notices) related to past-due and charged-off accounts as well as review of recordings of collections calls initiated manually and by predictive auto-dialing equipment. Our approach included an in-depth review of recent TCPA litigation to provide useful recommendations for the client to consider as management strengthens its TCPA policies and procedures.
Client Type
Credit Unions
Service Type
Independent Compliance Review
Website Compliance Review
Continued growth and the ensuing regulatory scrutiny led a large credit union to request a compliance review of its extensive website. CrossCheck focused the review on the advertising provisions of all applicable regulations, including those specific to credit unions, as well as potential UDAAP pitfalls. The review encompassed all pages and all links on the company’s website. The resulting report detailed regulatory findings and recommendations for correction. Of added value in this review is a list of weblinks that were either broken or resulted in an unexpected ‘landing,’ which could cause user frustration and increased complaints. For ease of correction, the report included both the link to the page and a screenshot highlighting the subject of the report comment.
Client Type
Credit Unions
Regional Bank ($10-$50 billion in assets)
Service Type
Independent Compliance Review
