Representative Engagements: Mortgage Operations and Compliance

M&A Due Diligence

  • Provided due diligence services to a financial buyer who was acquiring a mortgage banking firm and required insight into any compliance and operational risks from this business
  • Interviewed executive leadership to determine areas of highest risk
  • Analyzed compliance risk for originations, operations, closing, and marketing
  • Completed an overview of compliance management system (CMS)
  • Reviewed policies and procedures for vendor management
  • Evaluated investor concentration risk for secondary marketing and warehouse line
  • Assessed compliance with New York State Department of Financial Services (NYDFS) cybersecurity regulation under 23 NYCRR 500

Facilitated a Bank Merger

  • Provided staff augmentation and advisory services to the mortgage division of a to-be-acquired bank to make bank staff available for integration work and add stability during a time of accelerated attrition of acquired bank’s staff
  • Addressed outstanding compliance and audit matters across the business unit
  • Re-wrote all servicing procedures in acquiring bank’s format
  • Tested new Loan Origination Software (LOS), pre-implementation
  • Top 20 U.S. Bank

Implemented a New LOS

  • Studied capability of the new LOS selected by the client
  • Identified process changes necessary to optimize the value of the LOS to the client, created day one efficiencies, optimized customer experience, and ensured compliance
  • Analyzed efficiency and compliance of cross-vendor interactions (doc prep, title insurer, other)
  • Performed extensive testing
  • Documented procedures, trained client staff, and oversaw the implementation of the new LOS
  • New product implementation
  • Top 30 U.S. Bank Mortgage Originator

Managed a Servicing Transfer

  • Set standards of customer experience, compliance, reporting, and surveillance for an affinity group lender transferring servicing to a large non-bank servicer
  • Performed due diligence, gap analysis, and solution implementation to ensure standards were met
  • Optimized efficiencies to balance the goals of the client originator and the servicer
  • Top 30 U.S. Bank Mortgage Originator

Optimized Secondary Marketing 

  • Reviewed pricing and underwriting exception processing and outcomes to identify future profit opportunities and assess secondary market and fair lending risks
  • Designed and implemented procedural, governance, processes, and related documentation to enhance the value of exceptions to the lender
  • Improved the efficiency of the exception process through re-engineering
  • Provided benchmarking information
  • Top 20 U.S. Bank

Assessed Risk of an Origination Platform

  • Reviewed and tested effectiveness of policies, procedures, technology, and training processes to gauge the regulatory risk in a client’s residential mortgage origination business
  • Identified and defined control improvement opportunities through systemic and/or procedure, process, training change
  • Scored risk based on factors such as duration of control maturity, preventative or detective control, level of automation, and frequency
  • Scored testing results tied to impact on business drivers
  • Produced reporting arranged by operational segment, department, and/or specific regulation
  • Top 30 U.S. Bank Mortgage Originator

Safeguarded Department of Housing and Urban Development (HUD) Insurance Claims Filing

  • Reviewed records of defaulted Federal Housing Administration (FHA)-insured mortgage loans for compliance with HUD origination requirements prior to insurance claim filing to reduce False Claims Act (FCA) risk exposure
  • Calibrated results to a specific standard
  • Consulted with client to produce an agreed upon risk definition
  • Helped client alter their broader credit policies and assisted in the implementation to address gaps identified
  • Executed work in a production-type flow timetable
  • Top 5 U.S. Bank

Safeguarded Salability

  • Designed, implemented, and executed a pre-closing credit and compliance quality control review of jumbo residential mortgages being sold to a Top 5 U.S. Bank to ensure all loans originated for the program were saleable
  • Reviewed for adherence to our client’s credit and compliance standards as well as those of the investor
  • Calibrated and discussed issues with client to help them fine tune their process and training to produce efficiencies
  • Executed work in a production flow timetable
  • Top 30 U.S. Bank Mortgage Originator

Performed Matched Pair Testing for Fair Lending

  • Performed fair lending statistical analysis from client's loan data to produce a sample list of matched pairs
  • Re-underwrote the loan and reviewed any exception documentation to determine whether there was an explanation for pricing discrepancy or whether there could be a regulatory concern
  • Top 30 U.S. Bank Mortgage Originator

Re-engineered Home Mortgage Disclosure Act (HMDA) Reporting

  • Performed data extraction, analysis, mapping and verification (“scrub”) for complete year of originations and managed reporting and data submission
  • Identified data gaps and inaccuracies and engaged in root-cause identification and process reengineering
  • Performed data analysis throughout the year to assist client in addressing potential emerging compliance themes
  • Top 30 U.S. Bank Mortgage Originator

Independent Consultant for an Office of the Comptroller of the Currency (OCC) Foreclosure Review

  • Performed analysis to determine federal and state law compliance and compliance to Government-Sponsored Enterprise (GSE) programs
  • Testing included data sampling and document review
  • Top 30 U.S. Bank Mortgage Servicer

Independent Consultant for Multi-agency Foreclosure Review*

  • Performed analysis and testing to determine regulatory compliance of the past activities of a vendor to the servicing industry (activities included default servicing, foreclosure, loss mitigation, bankruptcy)
  • Interviewed key business leaders
  • Applied benchmarking
  • Top 5 Vendor to the Servicing Industry

*Federal Reserve, OCC, Federal Deposit Insurance Corporation (FDIC)

Loss Mitigation Review as Support to a Consumer Financial Protection Bureau (CFPB) Monitor

  • Performed complete analysis of the loss mitigation activities of a servicer for regulatory compliance
  • Identified defects and prepared servicer for implementation of remediation protocols
  • Top 30 U.S. Bank Mortgage Originator


B. Scott Fisher
Chief Executive Officer

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