A national mortgage lender sought to acquire several mortgage companies. Our client asked us to review samples of loans from each prospective acquiree to evaluate loan quality, for both underwriting and compliance, prior to moving forward on the acquisition.
Securitization Due Diligence
In anticipation of securitization, multiple clients have engaged CrossCheck to perform due diligence on non-QM portfolios. The reviews are designed to meet rating agency requirements and included analyses of credit, compliance, collateral, and data accuracy.
Mortgage Electronic Registration Systems, Inc. (MERS®) System to System Reconciliation
Mortgage servicers are required to reconcile its System of Record to the MERS® System data monthly or quarterly if servicing fewer than 1,000 mortgage identification number (“MIN”) records. CrossCheck completes this reconciliation quickly and seamlessly ensuring all the required data elements including “required and conditionally required fields” are reconciled to the MERS® system. Once the… Read more »
California Department of Financial Protection and Innovation (DFPI, formerly DBO) Per Diem Interest Audit
Assisted a large mortgage lender defend allegations by the Department of Business Oversight that it had not properly computed per diem interest on California loan closings. The lender engaged CrossCheck to perform an audit of a sample of loans selected by the DBO and recompute the per diem interest. Our findings and insights helped the lender favorably… Read more »
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… Read more »
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… Read more »
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… Read more »
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… Read more »
Compliance Management Systems (CMS)
As non-depository mortgage entities and fintechs align their internal control structures with the expectations of the CFPB, numerous clients have engaged CrossCheck to perform compliance management system (CMS) assessments of the two interdependent control components of an effective CMS which include: Board and Management Oversight; and Compliance Program, which includes: Policies and procedures; Training; Monitoring… Read more »
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… Read more »
CFPB MOU Remediation
After receiving a memorandum of understanding (MOU) from the CFPB, one of the largest independent mortgage originator/servicers engaged CrossCheck – upon CFPB non-objection – to conduct a look-back of several thousand loan modifications made over a two-year period. We reviewed each modification to determine if fees assessed and cash contributions granted as part of the… Read more »
False Claims Act Lawsuit
Realtors, on behalf of the federal government, brought a False Claims Act lawsuit against one of the largest mortgage servicers, alleging they had not properly performed HAMP modifications. CrossCheck reviewed and responded to the realtors’ allegations, providing expert testimony that helped the client achieve a favorable settlement.
Predatory Lending Litigation
A borrower sued the client, a national mortgage lender, alleging that the lender engaged in 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 type of… Read more »
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… Read more »
CFPB Readiness Exams
With 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 enabled the originator/servicer to remediate issues… Read more »
Internal Audit Plan Development and Risk Assessment
Continued growth and increased regulatory and investor scrutiny have prompted a number of mid-size, private non-depository mortgage servicers, originators, and fintech companies to implement an internal audit function. CrossCheck deploys experienced and certified internal auditors to assist with development of an internal audit plan including a risk assessment, audit schedule, and management and board reporting.… Read more »
Fair Lending and UDAAP Audit Program Development
One of the pillars of an effective fair lending compliance management system (FL CMS) is the independent review or audit of the fair lending and responsible lending program. We assisted the company’s internal audit function in developing audit programs to assess the effectiveness of fair lending and Unfair, Deceptive or Abusive Acts or Practices (UDAAP)… Read more »
HMDA Data Integrity
We have assisted numerous mortgage companies in validating the accuracy of Home Mortgage Disclosure Act (HMDA) data previously submitted or in preparation for an upcoming submission. Our approach to HMDA data errors and omissions testing integrates systemic data routines to identify conflicts between loan origination systems (LOS) and HMDA data. Identifying statistical anomalies or “red flags”… Read more »
