Services

Regulatory Compliance

Compliance Program Development
- Risk Assessments
- Consumer Protection Regulatory Compliance
- Policy and Procedure Builds Monitoring and Testing Programs
- Regulatory Filings and Submissions
- Regulatory Examination Support
- Responses to Examination Findings
- Compliance Program Efficiency Reviews
- Tailored Training Programs
- Anti-bribery and Corruption Compliance Programs
Ethics Programs
- Code of Ethics Development
- Enhancement of Ethics Program Controls
- Conflicts of Interest Controls
- Ethics Training
- Whistleblower Program Reviews or Development
- Case Management Assistance
- Ethics Program Audits
- Ethics Program Reviews, Assessments, and Implementation
Strengthening the Compliance Program
- Strategic Planning for Compliance
- Compliance Risk Management Program Evaluation and Enhancement
- Structure and Staffing Review
- Consumer Financial Protection Bureau (CFPB) Readiness Check
- Risk Assessments
- Risk Metrics and Reporting
- Control Identification and Enhancements
- Efficiency Evaluations
- Monitoring and Testing Implementation
- Board Training
- Third-Party Risk Management
TILA-RESPA Integrated Disclosure (TRID) Compliance
- Gap Analysis for Implementation and Testing Plans
- Development and Implementation of Testing Scripts for Pre- and Post- Implementation Evaluation
- Evaluation of Third-Parties
- Enhancement of Risk Management Controls
- Loan-level Reviews and Testing
- Design and Implementation of Processes for Application, Underwriting, Production, and Closing
- Design and Delivery of Training
UDAAP Readiness
- UDAAP Readiness Check
- UDAAP Risk Assessments
- UDAAP Complaint-Management Systems
- UDAAP Controls Review
- UDAAP Product Reviews
- UDAAP Audits
- New Product Due Diligence Reviews
- Monitoring and Audit Review
- Metrics and Reporting
- Training
Community Reinvestment Act (CRA)
Retail Sales Incentive Practices
Reviews and Lookbacks
- Complaint Management Reviews
- Sales Incentive Practice Assessments
- Marketing and Sales Reviews
- Deposit or Lending Operational Reviews
- Servicemembers Civil Relief Act (SCRA) and Military Lending Act (MLA) Review
- Fair Credit Reporting Act (FCRA) Reviews, including Credit Bureau Reporting and Data Usage
- Transactional Lookbacks (Regulation E, Credit Reporting)
- Business Continuity
Merger & Acquisition Readiness, Due Diligence, and Integration

Representative Engagements

FinTech Compliance

Short- and Long-term Strategic Advisory
Compliance Program Assessments
Compliance Program Development and Implementation
Policy and Procedure Builds
Audit and Examination Management and Support
Vendor Management Oversight and Due Diligence
Change Management and User Acceptance Testing (UAT) Enhancement
Complaint Handling and Oversight Reviews, Enhancements, and Performance
Development and Implementation of Corrective Action Processes
Compliance Management System (CMS) Assessments
Risk Assessments and Monitoring Programs (Compliance and UDAAP)
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) or Fair Lending Program Assessments
Fair Credit Reporting Act (FCRA) Reviews, including Credit Bureau Reporting and Data Usage
Due Diligence Process Assistance
Third-Party Risk Management
Strategic Advisory related to Acquisitions and Partnerships

Fair and Responsible Banking

Redlining Readiness Check
Risk Assessments
Program Evaluations
Statistical Analysis
Mystery Shopping, Matched Pair Testing, and Self-Testing
Community Reinvestment Act (CRA)
Developing and Improving Fair Lending and Community Reinvestment Act (CRA) Programs
Home Mortgage Disclosure Act (HMDA) LAR Processing and Filing
Compliance Management System (CMS) Program Builds and Assessments
Model Validation

Representative Engagements

Mortgage Operations and Compliance

Mortgage Operations and Compliance Advisory
- Mortgage Origination, Servicing, and Secondary Marketing Operational and Compliance Risk Assessments
- Loss Mitigation Compliance Analysis, Remediation, and Process Repair
- Merger and Acquisition Due Diligence and Integration
- Foreclosure and Loss Mitigation Risk Assessments
- Home Mortgage Disclosure Act (HMDA) Data Integrity and File Reviews
- Change Management for Mortgage Industry Participants
- Process Change and Improvement for Efficiency and Risk Management
- Training
- Technology Strategy and Integration
- Audit: Staff Augmentation and Training
- Servicing Transfer Compliance Testing
- TILA-RESPA Integrated Disclosure (TRID) Rule Compliance Implementation, Testing, and File Reviews
- Process and Procedure Writing
- Agency and Insurer Risk Assessment
- Vendor Management
Due Diligence
- Mortgage Credit Risk and Compliance Due Diligence for Business Acquirers and Whole Loan Acquirers, Insurers, and Servicers
Government Investigation and/or Whistleblower Response
- Risk Analysis including Data and Loan File Review
- Subject Matter Experts for Origination, Servicing (including Foreclosure), and Securitization
- Dollar Sizing of Potential Exposure
- Data Aggregation and Data Management Support
- Response Support
- Federal Housing Finance Administration (FHFA) and Federal Housing Administration (FHA)

Litigation Support

Expert Witness Services
- Testifying Experts with Extensive Industry Experience
- Data and File Analysis
- Mediation Statement and Expert Report Preparation
- Demonstrative Exhibit Preparation
- Support Team with Extensive Trial Experience
Government Investigation, Whistleblower Response, and Litigation Analysis
- Risk Analysis and Quantification
- Pre-Trial Investigation
- Variety of Subject Matter Experts, including Mortgage Industry and Market Manipulation
- Data Aggregation and Data Management Support
- Response Support
- Experience in Multiple Forums and Full Complement of Regulators
- Damages Estimates and Reports
- Litigation Document Management
Post-Enforcement Remediation and Support
- Multiple Engagements Serving as Monitor Under Consent Order
- Independent Review to Ensure Compliance with Settlement or Receivership
- Testing Protocol Design and Implementation
- Report Preparation and Data Analytics

Representative Engagements

Global Financial Crimes Compliance

Program Design, Assessment, and Implementation
- Design and Implementation of Compliance Programs
- Program Reviews, including Health Checks
- Department Structure and Staffing Assessments
- Policy and Procedure Development
- Acquisition/Merger Due Diligence
- Risk Assessments
- Risk Scoring Methodology Development
- Independent Audits
Governance
- Board of Directors and Senior Management Roles and Responsibilities
- Management and Board Reporting; Dashboard and Metrics Design
- Corporate Culture Reviews and Assessments
- First-, Second-, and Third-Line Roles and Responsibilities
- Training at all Levels—Board; Management; Employees
Customer Risk Profile
- Customer Segmentation
- High Risk Customer Methodology
- Know Your Customer (KYC)/Customer Due Diligence (CDD) Program
- Customer Identification Program (CIP)
- Enhanced Due Diligence (EDD) Program
- Correspondent Banking Due Diligence
Model Governance, Review, Implementation, and Validation
- Model Governance
- Model Documentation Procedure and Analysis
- Anti-Money Laundering (AML) Alerting Sanctions for Office of Foreign Assets Control (OFAC) Screening Tools Identification and Implementation
- Anti-Money Laundering (AML) Monitoring Rules/Scenarios, Identification, Calibration, and Analysis
- Sanctions (OFAC) Filters/Fuzzy Logic Rules Identification, Calibration and Analysis
Data Analytics and Remediation
- Data Integrity/Lineage Reviews
- Customer Data Quality Reviews
- Data Acquisition: Normalization
Regulatory Exams
- Exam Preparation
- Corrective Action Advisory and Remediation
Investigations and Lookbacks
- Financial Investigation Unit (FIU) Review
- Alert and Case Management Process Review
- Enhanced Due Diligence (EDD) and Transaction Lookbacks
- Suspicious Activity Reporting (SAR) Review
Staff Augmentation
- Staffing at all Levels: Chief Compliance Officer (CCO); Analyst; Auditor
Program Outsourcing
- All Program Areas from Oversight to Investigations
Enforcement Action Remediation
- Independent Compliance Monitorships/Consultancies
- Independent Compliance Reviews and Audits
- Independent Transactional Reviews (Lookbacks)
- Tactical Remediation Project Plans

Representative Engagements

Financial Markets Conduct and Compliance

Trading Room Conduct Remediation
- Review of Trading Management to Prevent and Cure Identified Misconduct
- Read-Across of Misconduct in a Trading Room’s Activities
- Survey of London Interbank Offered Rate (LIBOR), Foreign Exchange (FX) Benchmarks, and FX Sales Practices
- Assessment of Derivatives Client Suitability and Derivatives Risk Disclosures
- Evaluation of Treasury Auction Process and Communications
- Review of Litvak Risk, Sales Process, and Communications on Mortgage-Backed Securities (MBSs) and Collateralized Debt Obligations (CDOs)
- Analysis of Client Pricing Agreements and Documentation
- Provision of Culture Measurement Tools
Regulatory Enforcement Preparation and Remediation
- Internal Investigations
- Independent Monitor on Regulatory Investigations and Remediation
- Preparation for Regulatory Examination
- Assessment of First, Second, and Third Lines of Defense
- Review and Assessment of Regulatory Matters Requiring Attention (MRAs) and Matters Requiring Immediate Attention (MRIAs)
- Compliance and Audit Reviews
Trading Activities Surveillance and Business Controls
- Evaluation of Written Supervisory Procedures
- Review of First-Line-of-Defense Business Controls
- Tools to Review Trade and Communications at Scale
- Validation, Verification, and Certification of Algorithms and Code
- Qualitative Harm Surveillance Simulator
Legal Investigation and Settlement Support
- Expert Witness
- Trade Review
- Communications Review
- Industry Practice Review
- Provision of Subject Matter Experts (SMEs)
- Advanced Surveillance and Investigation Tools
Fixed Income and Currencies Compliance
- Review of Regulatory Requirements
- Assessment of Policies and Key Operating Procedures
- Evaluation of Supervision and Business Controls
- Review of Surveillance, Testing, and Controls
- Review of Compliance Advisory and SME Capabilities
Volcker Rule on Proprietary Trading
- Assessment of Volcker Proprietary Trading Compliance
- Risk Metrics Evaluation
- Review of Key Defining Internal Models: Customer-Facing Trade Ratio (CFTR), Reasonably Expected Near-Term Demand (RENTD), and Trading Book Hierarchy
- Full Review of Volcker Exemptions and Exclusions, such as “Solely Outside the United States” (SOTUS) versus “In-Scope” Determination
- Preparation for Regulatory Review
Dodd-Frank Act Title VII and Markets in Financial Instruments Directive (MiFID II)
- Assessment of Swap Dealers
- Survey of Swap Execution Facilities
- Analysis of Trade and Transaction Reporting
- Evaluation of Clearing, Margin, and Collateral
- Review of Applicability and Reach of MiFID II Rules into US Trading Rooms
Intercontinental Exchange London Interbank Offered Rate (LIBOR) Conduct and Compliance and LIBOR Replacement
- Remediation of LIBOR and other IBOR Misconduct
- Preparation for Implementation of LIBOR Plus
- Assessment of Implications for Replacement of LIBOR Benchmark Rate
- Project Management of LIBOR Benchmark Replacement
Comprehensive Spot and Electronic Markets Expertise, including Fixed Income, Equities, Rates/Benchmarks, Futures/Derivatives
Health Checks of International Banks’ Trading Activities
Design, Implementation, and Validation of Preventative Market Surveillance and Controls
Automated Trading and Pricing Algorithm Model Review and Validation
Culture, Conduct, Sales Practices, and Governance Reviews
Compliance Gap Analyses and Design of Compliance Remediation Programs, including MiFID II Compliance
Internal Investigations and Regulatory Remediation Planning and Implementation
Litigation Support

Operational and Third-Party Risk

Cybersecurity Strategy Development, Program Design, Implementation, and Ongoing Assessment
Incident Response Capability Assessments
Incident Response Program Development and Implementation
Cyber Incident Rapid Response including Interaction with Law Enforcement, Regulators, and Media; Notification Management; and Stakeholder Communications
Incident Response Planning and Rapid Response Program Development
Board Level Data Governance, Training, and Awareness
Data Risk Identification and Evaluation and Governance Framework Design
Privacy and Information Security
Enterprise Privacy Program Development and Implementation
Compliance Solutions for Multi-jurisdictional Privacy and Data Protection Requirements
Regulatory Change Management
Training and Awareness
Privacy Compliance Control Identification, Monitoring, Testing, and Reporting
Solicitation Management - Telephone Consumer Protection Act (TCPA) - and Customer Preference Administration
Third-Party Risk
Third-Party Rapid Assessment
Reverse Playbook Methodology and Framework
Third-Party Risk Program Development and Implementation
Pre-contract Compliance and Data Security Due Diligence
Post-engagement Compliance and Data Security Assessments
Due Diligence for Mergers, Acquisitions, and Dissolutions

Representative Engagements

Affiliated with Treliant Risk Advisors, Asurity Technologies is a RegTech software provider that reinvents compliance for competitive advantage.