AI Fair Lending Funnel Analysis and Decision Process Review
CrossCheck was engaged by a credit union to assess whether the use of its AI-supported underwriting solution altered fair lending outcomes across the full credit decision process. The analysis reviewed application outcomes from initial AI score assignment through automated decisioning, referral logic, and final manual review. Using proxy-based prohibited basis analysis and regression testing, we evaluated whether denial disparities emerged, increased, or declined at different stages of the underwriting funnel, allowing the client to see where risk was introduced, mitigated, or carried forward.
In addition to measuring overall disparities, we isolated marginally qualified applications and analyzed outcome transitions to determine whether AI testing results, credit union decision thresholds, or manual review processes affected similarly situated applicants differently. This analysis included comparing predicted and actual outcomes, identifying underwriting funnel decision points that warranted deeper review, and isolating how the credit union’s traditional underwriting criteria interacted with AI-enabled processes. The engagement gave the client a practical framework for ongoing AI solution monitoring and governance by explaining how AI model outputs, operational rules, and human intervention worked together to shape fair lending risk.
Client Type
Service Type
AI Model Output Testing and Underwriting Alignment Review
CrossCheck was engaged by a credit union to evaluate whether AI model outputs created elevated fair lending risk within the underwriting process. The review included analysis of AI model score disparity patterns, comparisons between the credit union’s instant approval thresholds and actual credit outcomes, and statistical testing of whether differences in model outputs across protected classes were significant. We also assessed average AI scores by prohibited basis group to determine whether the observed score differences warranted further investigation from a fair lending perspective.
To better understand how the AI testing results aligned with the lender’s existing underwriting framework, we used regression analysis to evaluate the extent to which traditional underwriting factors explained the AI score. In addition, we performed separate disparity testing on applications that qualified for instant approval and instant denial outcomes, to identify whether the credit union’s subsequent decision segmenting introduced or amplified risk. The analysis provided the client with a clearer understanding of how AI model outputs influenced credit decisioning, where disparities were concentrated, and what monitoring steps could strengthen ongoing governance of AI-assisted underwriting.
Client Type
Service Type
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 regulatory guidance and the relevant requirements of the FFIEC examination procedures. CrossCheck assessed the AML audit program commensurate with the company’s risk profile, focusing on the “four pillars” of AML compliance, including development of internal policies, procedures, and related controls; designation of a Bank Secrecy Act (BSA) compliance officer; implementation of an effective training program; and independent review for compliance. As part of the engagement, we also reviewed the company’s AML risk assessment for adequacy and completeness. The MSB received an audit report outlining findings and recommendations for a more robust and compliant AML program.
Client Type
Service Type
Auto Lending Compliance Review
CrossCheck performs auto lending compliance program reviews across the loan lifecycle, including origination, servicing, collections, and credit reporting processes. Such reviews include assessment of the quality of the lender’s compliance management system (CMS) for detecting and preventing violations of federal regulations applicable to auto loan origination or servicing, as well as identification of practices that increase the risk of consumer harm. CrossCheck’s reviews incorporate the CFPB’s examination procedures covering the following modules:
- Compliance Management System (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
Service Type
California DFPI Per Diem Interest Audit
CrossCheck assisted a large mortgage lender in responding to allegations by the California Department of Financial Protection and Innovation (DPFI), formerly the Department of Business Oversight (DBO), that it had not properly computed per diem interest on California loan closings. The lender engaged CrossCheck to perform an independent compliance audit of a sample of loan files selected by the agency and recompute the per diem interest. Our findings and insights helped the lender favorably resolve allegations with the DBO, improve operational processes, and avoid significant fines.
Client Type
Service Type
CFPB Compliance Consulting – Mortgage Lenders
Following implementation of the Dodd-Frank Act, mortgage companies became subject to examination by the Consumer Financial Protection Bureau (CFPB). Mortgage originators and servicers alike have engaged CrossCheck to assess their readiness for these examinations. Our approach for the review is based on the CFPB examination guidance and our findings enable originators and servicers to remediate issues prior to the exam, thereby improving their compliance management system (CMS) and reducing the potential for regulatory criticism.
Client Type
Service Type
Commercial Loan Portfolio Annual Review
CrossCheck has performed commercial loan review services for a variety of banks and financial institutions. These engagements have included assessments of underwriting and credit administration standards and practices; effectiveness of risk identification activities, including the ratings attributed to individual loan relationships and the overall portfolio; and risk management protocols to identify, measure, monitor, and manage portfolio risk. The reviews provide independent evaluation of institutional process and verification of the level of credit risk within the commercial loan portfolio.
Client Type
Service Type
Community Credit Needs Assessment (CCNA)
CrossCheck performed a community credit needs assessment (CCNA) of the client’s primary mortgage lending market, focused on majority-Black or Hispanic census tracts (MBHCTs). The evaluation included analyses of mortgage lending, demographic, socioeconomic, and housing characteristics. Key findings discovered through statistical analysis, community contacts, and local reports indicated significant community credit needs. The mortgage lending market analysis revealed distinct differences in product demand and borrower characteristics, with MBHCTs exhibiting unique needs and preferences compared to other tracts in the market. Geographic analysis showed how these needs varied regionally between MBHCT neighborhoods. Successful peer strategies and government loan programs were also reviewed to document existing products and services addressing the community credit needs. CrossCheck identified several opportunities for the client, including loan subsidy fund uses, financial education initiatives, community development partnerships, and targeted outreach efforts.
Client Type
Service Type
Compliance Policies and Procedures Development
As the regulatory environment and the requirements imposed on financial institutions continue to evolve, CrossCheck has been engaged by a variety of banks, fintechs, mortgage entities, and credit unions to develop, review, and enhance compliance policies and procedures. These engagements have included the development of required policies that previously did not exist and strengthening existing documentation to support governance, risk management, and internal controls.
Client Type
Service Type
CRA and HMDA Parity Analysis
CrossCheck assisted an intermediate bank in developing a Community Reinvestment Act (CRA) parity analysis to identify gaps in mortgage, small business, and small farm lending performance. Parity was established using owner-occupied mortgage properties and the distribution of businesses and farms for small business and small farm lending performance comparison. We conducted distribution analysis to identify deficiencies in the bank’s assessment area and at the branch level. The bank used the results to proactively address its HMDA and CRA lending performance.
Client Type
Service Type
CRA Performance Evaluation
CrossCheck prepared a Community Reinvestment Act (CRA) performance evaluation for an intermediate bank in anticipation of its upcoming CRA examination. The performance evaluation was based on the regulatory CRA exam procedures and described the bank’s efforts to meet the needs of the communities it serves. The engagement addressed the bank’s performance under the lending test, service test, investment test, and related community outreach efforts. Performance analytics incorporated performance context including demographics, peer performance, and other socioeconomic data.
Client Type
Service Type
Due Diligence – Commercial Loan Portfolio Review
CrossCheck was engaged to perform a due diligence review on an acquisition target’s commercial loan portfolio and other real estate owned to assess asset quality, collectability, and potential credit risk prior to purchase. CrossCheck’s review uncovered the lack of both adequate loan monitoring and basic loan administration procedures. This independent assessment allowed our client, the acquiring bank, to proceed with the transaction informed of the potential risks inherent in the portfolio.
Client Type
Service Type
Fair Lending and UDAAP Audit Program Development
CrossCheck assisted a mortgage company to develop an internal audit program to assess the effectiveness of its fair lending and UDAAP risk management efforts. The audit program addressed both loan origination and servicing processes, drawing on CFPB examination procedures and industry best practices. CrossCheck conducted management interviews to ensure a clear understanding of the products and services to tailor the audit program to the company’s activities. These interviews provided the ancillary benefit of added fair lending awareness for the management team and the internal audit function. The mortgage company received a customized audit program designed to address fair lending and UDAAP risks associated with its business model.
Client Type
Service Type
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 engagement was for CrossCheck to provide specialized fair lending expertise to the client’s audit team. The scope included program governance, roles and responsibilities, policies, monitoring, and analytics. Line-of-business interviews helped to identify risks associated with marketing, access to credit, credit risk management, and loan pricing. The bank’s audit team gained a stronger understanding of fair lending risks and controls, and management received valuable feedback to help improve the bank’s fair lending CMS.
Client Type
Service Type
Fair Lending Examination Response and Redlining Review
Following a regulatory fair lending examination, CrossCheck was engaged in an advisory role, working in partnership with a regional bank’s legal counsel. The engagement included support for responses to examiner requests for additional information, an independent review of redlining risk, and preparation for a potential referral to the Department of Justice (DOJ). The engagement provided independent analysis and strategic support during a period of elevated supervisory and enforcement risk.
Client Type
Service Type
Fair Lending Program Review
CrossCheck conducted a comprehensive evaluation of a regional bank’s fair lending compliance management system (CMS). The review included an assessment of board management and oversight, preventive and detective controls, complaint management, training, policy and procedures, change management, and third-party risk oversight. CrossCheck provided recommendations to strengthen the bank’s fair lending program, enhance control effectiveness, and support revisions to policies and procedures.
Client Type
Service Type
Fair Lending Statistical Risk Assessment and Advisory
CrossCheck advised a national lender on the development of statistical models used to assess fair lending risk associated with marketing, underwriting, pricing, and loss mitigation. The engagement included review of analytical results to assess and identify potential disparate treatment, disparate impact, and redlining risk. CrossCheck participated in client meetings to review model data requirements, analytical approach, methodology for identifying fair lending risks, and interpretation of results. Our advice and guidance resulted in modifications to existing models and development of new models to enhance fair lending risk management efforts, as well as internal business justification of specific practices.
Client Type
Service Type
False Claims Act Litigation Support – Mortgage Servicing
CrossCheck provided litigation support in a False Claims Act lawsuit involving HAMP mortgage servicing allegations against one of the largest mortgage servicers. The engagement included review of the relators’ allegations, analysis of HAMP servicing and loan modification practices, and expert testimony in support of the client’s defense. CrossCheck’s work helped the client evaluate servicing-related claims and supported a favorable settlement.
Client Type
Service Type
Fintech Compliance Management Consultation
Fintech companies engage CrossCheck to assess and develop compliance management systems (CMS) built to meet regulatory and partner bank expectations. Our reviews evaluate governance, compliance risk assessment, policies and procedures, training, monitoring and testing, consumer complaint response, and third-party oversight. The resulting recommendations help fintechs address control gaps, improve reporting and remediation practices, and sustain a robust fintech compliance system as products, partnerships, and regulatory expectations evolve.
Client Type
Service Type
Fintech Compliance Review – New Products and Services
A fintech company engaged CrossCheck to assist it with a review of its home equity line of credit (HELOC) program documents by counsel licensed in 48 states. CrossCheck utilized its relationships with financial services law firms to source local counsel in each state with the expertise to perform the state specific reviews and managed the process including negotiating the services and fees of local counsel on behalf of the client, providing instructions for the reviews, responding to questions, tracking status, deliverables, and managing client billing. As a result, the client was able to roll out its HELOC program nationwide quickly and cost-effectively, with a built-in network of legal counsel to support future needs.
Client Type
Service Type
GSE Repurchase Demand Review and Rebuttal Support
CrossCheck has assisted a number of clients that received repurchase demands from Fannie Mae and/or Freddie Mac. CrossCheck performed forensic reviews to verify the allegations in the GSE repurchase demands, and where appropriate, prepared rebuttal letters and supporting evidentiary files. CrossCheck’s work helped clients challenge repurchase demands and successfully rebut thousands of claims.
Client Type
Service Type
HMDA Data Integrity Review
CrossCheck has assisted numerous mortgage companies in validating the accuracy of HMDA data previously submitted or in preparation for an upcoming submission. Our approach to HMDA data error and omission testing integrates systemic data routines to identify conflicts between loan origination systems (LOS) and HMDA data. Identifying statistical anomalies or “red flags” compared to peers and/or national aggregate data is a first step that helps focus the review. Through this approach, we can ascertain the root cause of identified data issues, provide the framework for enhancing system controls, and enable automated corrections to the LAR, resulting in improved data integrity for current and future submissions.
Client Type
Service Type
HMDA Fair Lending Performance Review
CrossCheck performed a statistical analysis of a bank’s HMDA lending activity to identify 1) differences in levels of assistance based on the timing of decisions and final disposition of applications; 2) disparities in application outcomes, including origination, denial, and non-decisioned applications; 3) pricing variances related to the frequency and magnitude of differences in APR and rate spread; 4) steering of applicants to particular products or sales channels; and 5) redlining analysis to identify potential geographic and demographic gaps in higher minority geographies. The analysis provided the bank with results to further investigate through comparative file review, as well as information necessary to effectively manage fair lending performance risk.
Client Type
Service Type
Independent AML Audit Services
CrossCheck has performed independent AML audits for banks, fintechs, mortgage bankers, and consumer finance companies. Our approach is informed by applicable FFIEC examination guidance and FinCEN requirements. An AML/CFT audit provides management with an unbiased assessment of compliance with 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
Service Type
Industrial Bank Compliance and Third-Party Oversight
The unique relationships between an industrial bank and its strategic partners, including fintechs, require the bank to maintain an effective compliance management system (CMS) that includes a robust vendor management program with strong oversight of the operations and the CMS of its strategic partners. CrossCheck has completed CMS reviews for both sides of such relationships, ensuring that the bank’s CMS meets regulatory agency requirements while tailoring strategic partner reviews to their individual operations under the bank’s broader 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
Service Type
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 an audit charter, performing an audit risk assessment, and providing a multi-year internal audit plan, we assigned experienced internal audit consultants to execute the 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 consultant assigned brought 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, CrossCheck regularly provides reports to the Audit Committee of the Board of Directors and ongoing consultation to the institution as needed.
Client Type
Service Type
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 to develop internal audit plans, including risk assessments, audit schedules, and management and board reporting. CrossCheck also executes the plan and provides consultation as needed through fully outsourced or co-sourced arrangements. As a result, clients gain a clearer understanding of key operational and compliance risks within their organization and meet investor (e.g. Fannie Mae MORA), state, and CFPB requirements.
Client Type
Service Type
Loan and Credit Risk Process Review
A credit union experiencing rapid growth in its member business loan portfolio requested an independent review of its business lending portfolio and related loan policies and procedures to ensure adherence to safety and soundness expectations. While overall policies and procedures were satisfactory, CrossCheck recommended enhancements to loan review procedures and compliance with the Flood Disaster Protection Act and implementing regulations. Our review helped strengthen the institution’s business loan risk management process and related flood compliance procedures, reducing exposure to potential monetary penalties.
Client Type
Service Type
Loan Exception Policy and Procedure Review
CrossCheck conducted an independent review of a bank’s updated loan exception tracking policy and procedures following criticism from its prudential regulator. Applicable regulatory requirements, prudent business practices, and CrossCheck’s years of experience were the basis for recommendations to further enhance controls and processes and meet regulatory and business requirements.
Client Type
Service Type
Loan Modification Expert Witness and Litigation Support
Counsel for a top-five bank engaged CrossCheck in several cases involving denied HAMP loan modifications. CrossCheck reviewed the underlying servicing files, prepared an expert report, and provided deposition testimony that resulted in favorable settlements for the bank.
Client Type
Service Type
Loan Modification Expert Witness Support
In a class action regarding HAMP loan modifications against one of the largest banks, counsel engaged CrossCheck to conduct a mortgage servicing file review, prepare an expert report, and provide deposition testimony. CrossCheck’s expert witness support contributed to the defense’s successful opposition to class certification.
Client Type
Service Type
MERS Independent Audit and Quality Assurance Review
Institutions with more than 1,000 mortgage loans registered with Mortgage Electronic Registration Systems, Inc. (MERS®) are required to have an independent third party monitor their process for obtaining, retaining, reconciling, and submitting mortgage registration data against their MERS quality assurance plans. CrossCheck has performed this role for a number of servicers, providing both the servicer and MERS with an unbiased evaluation of the servicer’s procedures for complying with MERS rules and requirements. Additionally, as servicers near the 1,000 registered loan threshold CrossCheck has assisted in developing and implementing the procedures needed to successfully meet the MERS annual requirements.
Client Type
Service Type
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 fewer than 1,000 mortgage identification number (MIN) records. CrossCheck performs this system-to-system reconciliation quickly and seamlessly, ensuring all required data elements including “required and conditionally required fields” are reconciled to the MERS system. Once data extracts are provided, CrossCheck’s data engineers complete the reconciliation and provide detailed reports of the differences identified so they can be remediated.
Client Type
Service Type
Mortgage Fraud and Repurchase Review
The mortgage subsidiary of one of the nation’s largest banks engaged CrossCheck to perform a forensic review of residential mortgage loans acquired from various mortgage lenders and correspondent banks. Our mortgage fraud specialists reviewed the loans to determine whether material misrepresentation existed, which would result in a request to repurchase the loan. CrossCheck determined on which loans repurchase should be requested and prepared the supporting evidentiary files, resulting in millions of dollars in mortgage putbacks.
Client Type
Service Type
Mortgage Loan Modification File Review & Remediation
After receiving a CFPB memorandum of understanding (MOU), one of the nation’s largest independent mortgage originators and servicers engaged CrossCheck, upon CFPB non-objection, to conduct a look-back review of several thousand loan modifications made over a two-year period. CrossCheck reviewed each modification to determine if fees assessed and cash contributions granted as part of the approved loan workout were calculated and disclosed properly to the borrower. Detailed reporting, including identifying refunds to affected borrowers, was provided to the CFPB. As a result, the client was able to complete required remediation and satisfy CFPB expectations in a timely manner.
Client Type
Service Type
Mortgage Operations Audit and Risk Assessment
CrossCheck performed an independent assessment of a client’s mortgage and home equity operations. The scope and objective of this review included an assessment of compliance with applicable consumer and safety and soundness regulations, evaluation of internal controls, determination of adherence to and effectiveness of the bank’s policies and procedures, and comparison to industry standards and best practices. This review provided an unbiased evaluation to strengthen operations and reduce overall risk exposure.
Client Type
Service Type
Mortgage Portfolio Review and Acquisition Due Diligence
A national mortgage lender engaged CrossCheck to perform a comprehensive portfolio purchase loan review as part of its acquisition of several mortgage companies. Examining loan samples from each prospective acquiree, CrossCheck evaluated loan quality, adherence to underwriting standards, and regulatory compliance. By identifying potential risks and confirming the portfolios met the lender’s quality expectations, we provided actionable insights to support informed acquisition decisions.
Client Type
Service Type
Mortgage Servicing Compliance Reviews
CrossCheck has conducted numerous default servicing and foreclosure look-back loan file reviews for mortgage servicers in connection with regulatory requirements tied to the 2011 Consent Orders issued to major loan servicers. Each review included CFPB mortgage servicing requirements related to early intervention with delinquent borrowers, continuity of contact, loss mitigation procedures, and foreclosure processing. These loan reviews have kept clients in compliance with regulatory requirements and allowed them to improve their operational controls.
Client Type
Service Type
Mortgage Servicing Review
One of the nation’s largest banks, serving as trustee for various mortgage-backed securities, engaged CrossCheck to perform an independent review of the servicer for the trust’s loans. The review provided the trustee with a reliable understanding of servicer performance, servicing controls, and overall servicing effectiveness.
Client Type
Service Type
Mortgage-Backed Securities Expert Witness and Loan Review
Mortgage-backed securities investors, including government-sponsored enterprises regulated by the FHFA, have filed actions under the Securities Act of 1933 and various state investment acts. Defendants’ counsel have retained CrossCheck to provide loan file review and expert witness testimony in many of these cases. We review the mortgage loan files underlying the security to evaluate the original underwriting and due diligence process and determine the consistency of the loan portfolio’s attributes with security offering documents. CrossCheck has utilized its experience with loan products and underwriting standards to provide evaluations relevant to the historical context in which the loans were originated. Our work has culminated in expert reports, deposition testimony, and trial testimony.
Client Type
Service Type
MSB Compliance Management System and Consumer Lending Audit
A money services business (MSB) and small-dollar lender engaged CrossCheck to perform an audit of its compliance management system (CMS) and consumer lending practices, including loan origination, payment processing and servicing, returned item processing, and credit bureau reporting. The review assessed the effectiveness, accuracy, and timeliness of the client’s compliance controls and processes. CrossCheck provided recommendations for policy and control improvements, as well as best-practice solutions to mitigate audit findings and their associated risks. The MSB received a report outlining regulatory findings and improvements to their process to help deter future regulatory issues and improve operational efficiencies.
Client Type
Service Type
Post-Closing Quality Control and Denied Applications Review
To assure the quality and integrity of its consolidated student loan originations, a bank engaged CrossCheck to perform post-closing quality control reviews on a sample of its monthly originations and denied applications. CrossCheck reviewed the underwriting and compliance performance of the loans and provided monthly reporting with findings and trend analysis. As a result, the bank gained greater confidence that its student loans and the securities they backed conformed to the bank’s quality standards and market expectations.
Client Type
Service Type
Post-Purchase Loan Portfolio Review
Following a client’s acquisition of the assets of a failed bank, CrossCheck performed a credit and loan documentation review of the acquired portfolio and interviewed loan department personnel from the failed bank. The review uncovered issues and documentation errors that posed credit and financial risk to our client. Our review provided the information needed to support ongoing administration of the acquired loans thereby mitigating future loss exposure.
Client Type
Service Type
Predatory Mortgage Banking Litigation and Underwriting Review
A borrower sued the client, a national mortgage lender, alleging predatory lending and loan flipping. CrossCheck reviewed the underwriting of the subject mortgage loan and provided expert opinions on the quality of the underwriting (including the borrower’s ability to repay), benefit to the borrower, and suitability of the loan product. As a result, the client was able to achieve a favorable settlement of the case.
Client Type
Service Type
Redlining Risk Assessment for Small Business Lending
CrossCheck assisted a client by analyzing three years of small business lending data to identify potential redlining risk, including potential geographic and demographic gaps in lending patterns concentrated in higher minority geographies. We developed a profile for each of the client’s Community Reinvestment Act (CRA) assessment areas that included:
- An overview of the concentration of majority-minority census tracts (MMCT), business demographics, and the competitive environment to provide relevant performance context in the lending market;
- An annotated map of the distribution of the client’s small business origination activity relative to MMCTs and its branch footprint;
- A comparative analysis to identify statistically significant disparities in lending to MMCTs between the client and aggregate small business lending patterns as reported under the CRA; and
- An assessment of residual redlining risk evaluating statistical disparities after considering relevant mitigating factors, such as competitive factors that influence MMCT penetration or planned initiatives that are expected to enhance performance.
The analysis and recommendations CrossCheck provided positioned the lender to better ensure compliance with fair lending laws, mitigate risk, improve community relations, and thoroughly prepare for its upcoming CRA exam.
Client Type
Service Type
Regulatory Compliance Training
Banks, fintechs, mortgage lenders, and credit unions have engaged CrossCheck to design and deliver regulatory compliance training programs for business lines, senior management, and board committees. Training has addressed BSA/AML, HMDA, CRA, fair lending, ECOA, loan servicing, TRID, UDAAP, FCRA, and other high-risk regulatory areas with content tailored to specific roles, risks, and operational realities. These engagements have helped clients strengthen internal training curriculums, procedural documentation, and regulatory preparedness.
Client Type
Service Type
Residential Mortgage Due Diligence
CrossCheck was engaged by a regional bank to perform due diligence reviews of mortgage loan samples from three proposed separate bulk whole loan purchases. The portfolios consisted primarily of conventional and jumbo mortgage loans, and the bank requested an assessment of compliance with federal and state regulatory requirements. CrossCheck examined more than 200 compliance data points, including requirements under Regulation Z, Regulation X, TRID, flood insurance, private mortgage insurance, and Higher-Priced Mortgage Loan requirements, as well as applicable state disclosures across 34 states. At the conclusion of the review, CrossCheck delivered a summary of findings identifying high-, medium- and low-risk issues for each loan so the bank could assess acceptable risk levels for each of the bulk whole loans considered for purchase.
Client Type
Service Type
RMBS Third-Party Review and Settlement Evaluation
CrossCheck partnered with a major litigation support firm to provide a third-party fairness opinion on a proposed settlement between an RMBS issuer and various investor groups. CrossCheck supervised the review of several thousand loans sampled from multiple RMBS trusts to evaluate the proposed settlement amount. The work resulted in approval of the proposed settlement.
Client Type
Service Type
Second-Lien Portfolio Repurchase and Servicing Review
A large regional bank that purchased a portfolio of second-lien loans on a servicing-retained basis was concerned that the original underwriting was not as represented and was dissatisfied with the servicing. CrossCheck reviewed the loan origination and servicing contracts to assess each party’s rights, including repurchase and servicing transfer, and performed a thorough review of the origination and servicing files. We provided opinions regarding servicing in accordance with the contract and industry-standard practices. We also evaluated underwriting exceptions, compliance issues, and misrepresentation. As a result, the client was able to negotiate a favorable settlement and transfer the portfolio to another servicer.
Client Type
Service Type
Securitization Due Diligence Portfolio Review
In anticipation of securitization, multiple clients have engaged CrossCheck to perform independent due diligence reviews of non-QM portfolios. The reviews are designed to meet rating agency requirements and include analysis of credit, compliance, collateral, and data accuracy.
Client Type
Service Type
TCPA and FDCPA Debt Collection Compliance Review
Due to the growth in class action Telephone Consumer Protection Act (TCPA) litigation and settlements, the client engaged CrossCheck to perform a targeted review of its debt collection practices. The engagement covered the client’s internal collection activities and oversight of third-party servicers and collection agents, including review of TCPA and Fair Debt Collection Practices Act (FDCPA) policies and procedures, internal compliance monitoring, and transaction testing. Testing focused on written collections letters and notices for past-due and charged-off accounts, as well as recordings of collections calls initiated manually and through predictive auto-dialing technology. CrossCheck also reviewed recent TCPA litigation to provide useful recommendations as management strengthened its TCPA policies and procedures.
Client Type
Service Type
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 a quarterly process to select and review a sample of the bank’s new loan production, stratifying the sample for higher-risk issues and out-of-tolerance situations that could result in expensive customer reimbursements. CrossCheck identified the root causes of many issues and recommended operational enhancements to reduce recurring errors. Management used the trending analysis reports we provided to track progress over time and implement operational changes to strengthen compliance going forward.
Client Type
Service Type
UDAAP Compliance Review of Debt Protection Products
Due to regulatory concerns related to UDAAP compliance, a regional bank engaged CrossCheck to assist with a multi-phase review of its debt protection product administration, including a look-back review of thousands of loans originated with debt protection over several years. We provided project management and a dedicated team of 12 consultants to develop the review methodology, train reviewers, oversee quality assurance, and deliver management reporting throughout the engagement. The review included detailed analysis of customer activity and loan servicing over the life of each loan to identify potential customer harm and inform remediation decisions. Based on that review, CrossCheck provided management with the information needed to evaluate its practices and support corrective action to mitigate future consumer risk.
Client Type
Service Type
Website Advertising and UDAAP Compliance Review
A large credit union engaged CrossCheck to perform a compliance review of its extensive website in response to increased growth and regulatory scrutiny. CrossCheck focused the review on the advertising provisions of all applicable regulations, including those specific to credit unions, as well as potential UDAAP risks. The review encompassed all pages and all links across the website. The resulting report detailed regulatory findings and recommendations for correction. As an added value, the review also identified broken or misdirected links that could cause member frustration and increase complaints. For ease of correction, the report included the relevant page link and a screenshot highlighting each issue.
Client Type
Service Type