Employ Independent Internal Audit & Testing Programs

Independent internal audit and testing programs deliver rigorous, defensible insight into the effectiveness of governance, risk management, and control frameworks, helping senior leaders validate performance, identify gaps, and demonstrate accountability to regulators and boards.

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Independent Reviews for Informed Oversight

When objective results are key, an independent review and test of processes and controls will provide the input key stakeholders require to execute their mandate.

Regulatory Compliance

Monitoring, Audit, or Targeted Loan or Deposit Compliance Reviews

Review the institution’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.

Compliance Risk Assessment

Identify and risk-rate compliance risks and controls for a refined focus.

Compliance Policy & Procedure Review/Development

Establish and incorporate compliance requirements and responsibilities into business processes.

Anti-Money Laundering/Combatting the Financing of Terrorism (AML/CFT) Services

CrossCheck performs AML/CFT audits and risk assessments required by the FFIEC, prudential, and state regulators for institutions every 12-18 months, or when changes to products/services occur.

Fair Lending

Fair Lending Program Review/Audit

CrossCheck conducts independent fair lending program reviews and audits to evaluate 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 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 institutions validate decision processes and demonstrate fair, consistent treatment of all applicants.

Internal Audit

Internal Audit Risk Assessment & Audit Plan Development

Identification and prioritization of risks allows you 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 institutions. 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 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 the 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.

Compliance audits we perform:

Consumer deposit and lending regulations
Consumer deposit products and services
Loan origination and loan servicing regulations
Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulations
Advertising and website regulations

MERS Audit, Quality Assurance, & Reconciliation Services

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.

Meet Your Internal Audit Experts

Tracey Levandoski

Managing Director

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Heidi Wier

Managing Director

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Wendy McMillan

Director

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Jim Treacy

Director

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Internal Audit & Testing FAQs

Why does independence matter in internal audit and testing?

Independence is critical to ensuring audit results are objective, defensible, and trusted by regulators, boards, and senior management. CrossCheck executes internal audits in accordance with the standards set out by the Institute of Internal Auditors (IIA), which defines internal audit as an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes. This objectivity strengthens governance, enhances credibility with examiners, and provides leadership with reliable insight to support oversight and decision-making.

How does an independent audit differ from internally conducted testing?

While internal teams often focus on process execution and monitoring, independent audits provide an assessment by individuals who are not involved in the daily execution or second line monitoring process. . Independent reviewers challenge assumptions, validate control design and effectiveness, and assess outcomes—not just adherence to procedures. This approach often surfaces systemic issues or emerging risks that internal teams, due to familiarity or resource constraints, may not fully identify.

In what situations is an independent audit most valuable?

Independent audits are especially valuable during periods of regulatory change, organizational growth, mergers and acquisitions, new product launches, or following examination findings. They are also critical when boards or regulators require unbiased assurance. In these scenarios, independent testing provides leadership with confidence that risks are understood, controls are effective, and remediation efforts are appropriately prioritized.

How do independent audits support board and committee oversight?

Independent audit results provide boards and committees with clear, unbiased insight into the effectiveness of governance, risk management, and controls. Reporting is structured to support oversight responsibilities, highlight material risks, and inform strategic discussions. This transparency enables boards to challenge management constructively, demonstrate due diligence, and fulfill fiduciary and regulatory expectations.

How do you ensure audit scope aligns with our risk profile?

Audit scope is developed through a risk-based approach that considers your business model, regulatory environment, prior findings, and strategic priorities. We focus on areas of highest impact and regulatory sensitivity, ensuring audit resources are applied where they provide the greatest value. This alignment ensures results are both practical and relevant to leadership decision-making.

How do independent audits help identify root causes, not just findings?

Rather than stopping at surface-level observations, independent audits analyze underlying processes, governance structures, and control dependencies. This root-cause approach helps management understand why issues occur and how to remediate them sustainably. The result is more effective corrective action and reduced likelihood of repeat findings.

How do independent audits integrate with existing internal audit or compliance functions?

Independent audits are designed to complement—not replace—existing functions. We coordinate with internal audit, compliance, and risk teams to avoid duplication, leverage existing work, and enhance overall coverage. This collaborative approach strengthens the control environment while preserving independence and efficiency.

What makes your approach to independent audit and testing different?

Our approach combines deep regulatory expertise, practical industry experience, and a focus on actionable outcomes. We understand how regulators evaluate controls in practice and design audits that balance rigor with relevance. Clients value our ability to translate complex findings into clear, executive-level insight that supports confident decision-making.

Representative Engagements

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Banks, Credit Unions, Mortgage Bankers, Consumer Finance

TRID Compliance Monitoring and Testing

CrossCheck was engaged to perform quarterly monitoring of a bank’s compliance with the Truth in Lending and RESPA Integrated Disclosure (TRID) requirements. We established...

Banks, Credit Unions, Mortgage Bankers

MERS System-to-System Reconciliation

Mortgage servicers are required to reconcile their System of Record to the Mortgage Electronic Registration Systems, Inc. (MERS®) System data monthly, or quarterly if they service...

Banks, Credit Unions, Mortgage Bankers

Fair Lending Compliance Management System (CMS) Audit

CrossCheck was engaged to perform an audit of a regional bank’s fair lending CMS in coordination with the internal audit department. The objective of the...

Banks, Credit Unions, Mortgage Bankers

Internal Audit Co-Sourcing

In response to growth and increased regulatory scrutiny, a client engaged CrossCheck to assist with the implementation of an internal audit function. After developing...

Consumer Finance

AML Audit for MSB and Small-Dollar Lender

A money services business (MSB) and small-dollar lender requested an independent audit of its anti-money laundering (AML) compliance program. The engagement was based on...

Mortgage Bankers, Fintech, Industrial Banks

Internal Audit Plan Development and Risk Assessment

CrossCheck has supported a range of mid-size non-depository mortgage servicers, originators, and fintech companies to establish an internal audit function. We deploy experienced, certified internal auditors...

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Independent Audit Services

Connect with an experienced, independent team to strengthen assurance, enhance credibility with regulators and boards, and gain clear, actionable insight that supports confident decision-making across your most critical compliance and risk initiatives.

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