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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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