A community credit needs assessment (CCNA) was performed 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 […]
Due Diligence Review of Residential Mortgage Loans
We were engaged by a regional bank to review a sample of loans from three proposed separate bulk whole loan purchases. The bank requested we determine whether the portfolios which were predominately conventional and jumbo loans, were originated in compliance with regulatory requirements. All disclosures required by Regulation Z- Truth-in-Lending and Regulation X – Real […]
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 […]
Fair Lending Program Review
We conducted a comprehensive evaluation of the bank’s fair lending compliance management system (FL CMS). The review included an assessment of board management and oversight, preventive and detective controls, complaint management, and third party risks. We provided recommendations to enhance the bank’s fair lending program and assisted in the revision of policies and procedures.
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) and Debt Protection Products
Due to regulatory concerns related to UDAAP compliance, the bank requested CrossCheck assist with a multi-phased review of its administration of debt protection products including a look-back of thousands of customer loans with debt protection originated over several years. We provided a project manager and a team of a dozen consultants.The project manager assisted in […]
Truth in Lending and RESPA Integrated Disclosure (TRID) Compliance Monitoring
With all the challenges and nuances of the new Know Before You Owe (TRID) rules, management requested CrossCheck perform quarterly monitoring of its compliance with the 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 […]
Mortgage Electronic Registration Systems, Inc. (MERS®) Independent Audit
Institutions with more than 1,000 mortgage loans registered with 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. We have performed this role for a number of servicers, providing both the servicer and MERS® with an unbiased evaluation of […]
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 […]
Fair Lending Advisory
We provided fair lending advisory services to a national lender on development of statistical models designed to assess fair lending risk associated with marketing, underwriting, pricing, and loss mitigation. Assistance included the review of analytical results to assess and identify potential risk of disparate treatment, disparate impact and redlining. One of our fair lending practice […]
Post Closing Quality Control/Denied Applications
Wishing to assure the quality and integrity of its consolidated student loan originations, a bank has engaged CrossCheck to perform quality control reviews on a sample of its monthly originations and denials. CrossCheck reviews the underwriting and compliance of the loans, and provides a monthly report on its findings, which includes trending analysis. As a […]
Loan Exception Policy and Procedure Review
CrossCheck conducted an independent review of the bank’s updated policy and procedure for the tracking and reporting of loan exceptions pursuant to 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.
Post-Purchase Portfolio Review
Upon a client’s acquisition of the assets of a failed bank, CrossCheck performed a credit and documentation review of the acquired loans and interviewed loan department personnel at the failed bank. The review uncovered issues and loan documentation errors that posed credit and financial risk to our client. Our review provided the information needed to […]
Due Diligence Review
CrossCheck was engaged to perform an assessment of an acquisition target’s commercial loan portfolio and other real estate owned to identify concerns regarding the quality and collectability of the portfolio 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 […]
Commercial Loan Portfolio Annual Review
CrossCheck performs reviews of an institution’s commercial loan portfolio that includes assessment of underwriting and credit administrations 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 review provides the institution with […]
Foreclosure Management Look-Backs
CrossCheck has executed numerous default management and foreclosure reviews. The objectives for these reviews aligned with the lookback requirements outlined in the Consent Orders issued to the 14 largest loan servicers in 2011. Each review included the requirements set forth by the CFPB related to early Intervention with delinquent borrowers, continuity of contact, loss mitigation […]
Compliance Policy 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 mortgage entities and community banks to review and enhance compliance related policies and procedures. This has also included the development of required policies that previously did not exist, enabling the client to strengthen […]
Training
Clients taking a proactive approach or responding to regulatory finding have engaged CrossCheck to prepare and conduct a variety of training sessions for business lines, senior management, and board committees. Training topics included Home Mortgage Disclosure Act; Community Reinvestment Act requirements; Bank Secrecy/Anti-Money Laundering, and loan servicing rules. As a result of the training, clients […]
Mortgage Servicing Review
One of the nation’s largest banks, serving as trustee on various mortgage-backed securities, wanted to assess the performance of the servicer of the trust’s loans. CrossCheck performed this review, allowing the trustee to have a reliable understanding of the servicer’s performance.
Mortgage-backed Securities Settlement Evaluation
CrossCheck partnered with a major litigation support firm to provide an opinion as to the fairness of a proposed settlement between an RMBS issuer and various investor groups. CrossCheck supervised the review of several thousand loans sampled from multiple RMBS trusts in order to evaluate the proposed settlement amount. The work resulted in approval of […]
HAMP Expert Testimony
Counsel for a top-five bank engaged CrossCheck on several cases to review plaintiffs’ declined HAMP modifications. We prepared an expert report and provided deposition testimony, resulting in favorable settlements for the bank.
HAMP Class Action
A plaintiff brought a class action regarding HAMP modifications against one of the largest banks. Counsel engaged CrossCheck to review the mortgage servicing files. We prepared an expert report and provided deposition testimony, which resulted in denial of class certification.
RMBS Investor Litigation
Mortgage-backed securities investors, including government-sponsored enterprises regulated by FHFA, have filed actions under the Securities Exchange Act of 1933 and various state investment acts. Defendants’ counsel has retained CrossCheck to provide loan file review and expert testimony on many of these cases. We review the mortgage loan files underlying the security to evaluate the original […]
Anti-Money Laundering/Countering the Financing of Terrorism
CrossCheck performs Anti-Money Laundering/Countering the Financing of Terrorism 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 […]
Fair Lending Examination Assistance
Subsequent to a regulatory examination, we were engaged in an advisory role and in partnership with the bank’s legal counsel. Assistance included responses to examination requests for additional information, independent review of redlining risk and preparation for potential referral to the Department of Justice.
Fair Lending Program Audit
We were engaged to perform an audit of the bank’s fair lending compliance management system (FL CMS) in coordination with the internal audit department. The objective of the engagement was for CrossCheck to provide deeper expertise to the audit team. The scope of the audit included program governance, roles and responsibilities, policies, monitoring, and analytics. Line […]
CRA Performance Review
We prepared a Community Reinvestment Act (CRA) performance evaluation for the bank in anticipation of its upcoming CRA examination. The performance evaluation is based on the regulatory CRA examination procedures and describes 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, […]
Fair Lending Performance Review
We performed an analysis of the 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) […]
CRA Parity Analysis
We assisted the 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 properties for mortgage and the distribution of businesses and farms for small business and small farm lending performance comparison. Distribution analysis identified deficiencies in the […]
Mortgage Operations Audit
The client requested CrossCheck perform an assessment of its 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 […]
Second Lien Portfolio Repurchase Review
A large regional bank, who had 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 understand each party’s rights (e.g. repurchase, termination of servicing) and performed a […]
Mortgage Fraud Review
The mortgage subsidiary of one of the nation’s largest banks requested a forensic review of residential mortgage loans acquired from various mortgage lenders and correspondent banks. CrossCheck’s team of mortgage fraud experts reviewed loans to determine the existence of material misrepresentation, which would result in a request to repurchase the loan. CrossCheck determined on which […]
GSE Repurchase Reviews
CrossCheck has assisted a number of its clients who received repurchase requests from Fannie Mae and/or Freddie Mac. CrossCheck performed a forensic review to verify the allegations in the GSE repurchase demand. Where appropriate, CrossCheck prepared the rebuttal letter and supporting evidentiary file, successfully rebutting thousands of repurchase demands.
