Representative Engagements: Compliance and Fair Lending

  • Conducted a TILA-RESPA Integrated Disclosure (TRID) operations and process review for the purpose of developing a Testing Plan, Testing Scripts, and User Acceptance Testing protocols that would confirm compliance with the Consumer Financial Protection Bureau’s (CFPB’s) TRID rule. The support provided by Treliant included a review of written policies and procedures, operations, and processes on a pre- and post-origination basis. Treliant also completed an assessment of vendor processes associated with the TRID implementation.

  • Assisted a regional bank to address deficiencies and opportunities for systemic enhancements of its fair lending data through loan file review and research, resulting in recommendations to ensure the accuracy of the client’s Community Reinvestment Act (CRA) and Home Mortgage Disclosure Act (HMDA) submission data and analytics.

  • Evaluated a national financial institution’s document and information production for the CFPB, all compliance policies and procedures, training programs, monitoring programs, compliance resources, and functions, resulting in recommendations for improvement.

  • Engaged by a non-bank lender to provide assistance to meet CFPB expectations for risk governance. Treliant performed a review of the company’s lending, marketing, servicing, and collection practices at its title loan branches. Services included enhancing operational procedures, building out the compliance management system, and customizing management training.

  • Performed a comprehensive risk assessment for a national lender of all compliance practices. Services included a review of emerging issues surrounding Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) and the CFPB, an assessment of UDAAP best practices, and the creation of an action plan to improve the client’s regulatory compliance policies to meet UDAAP, CFPB, and other national standards.

  • Performed a Fair Debt Collection Practices Act (FDCPA) change management initiative for a large bank while matching the goals of its business unit with the proposed new FDCPA rules. Services included documenting expected rule changes, conducting training seminars, developing a project plan, developing training for future employees, gap analysis, assessing current technology and systems, and providing recommendations for ranking risk.

  • Assessed a regional bank’s compliance program to determine if the program had the optimum organizational structure, staffing, responsibility assignments, designations of formalized accountability, and personnel. Treliant also provided recommendations to improve program efficiency, effectiveness, and flexibility to adapt rapidly to changes in regulations, products, services, and structure.

  • Provided strategic and tactical support to a major credit card issuer to improve its regulatory compliance program.

  • Delivered four comprehensive training programs at a large financial institution covering UDAAP. Extensively utilizing case studies, these UDAAP University programs resulted in employee-wide understanding of UDAAP regulatory requirements.

  • Delivered compliance program training to a growing mortgage company related to all consumer protection laws and regulations. Services included providing guidance on activities affecting similar institutions, best practices, recent industry developments, and expertise on similar training exercises, resulting in a company-wide understanding of federal regulations and preparation for an upcoming Federal Deposit Insurance Corporation (FDIC) examination.

  • Conducted a comprehensive review for a Top 5 US bank of its retail and credit card product offerings and compliance practices. The review included insurance, ancillary products and services, and promotions and marketing, resulting in recommendations for action to ensure compliance with state and federal regulations.

  • Provided an assessment of a Top 10 US financial institution’s complaint management system to review its baseline state and perform a gap analysis between the system and CFPB recommendations, resulting in steps to strengthen the system.

  • Conducted statistical testing of a regional bank’s HMDA data (including the HMDA Loan Application Registers of both the bank and its mortgage companies) for protected class disparities in areas including race, ethnicity, and gender. Testing consisted of HMDA data, denial rates, pricing, identification of outliers, and file reviews, resulting in recommendations.

  • Conducted a comparative analysis for a regional bank regarding its product offerings and compliance program, to compare the bank’s fair lending performance to its peers’, resulting in the identification of potential redlining concerns.

  • Evaluated a Top 10 bank’s readiness for a CFPB examination. Treliant reviewed compliance in light of past FDIC examination reports, conducted a Consent Order gap analysis, and analyzed lender-placed insurance practices, resulting in recommendations for improvement in preparation for examination.

  • Performed a statistical analysis for a major bank mortgage lender regarding its lending practices, to conduct a disparate impact and remediation analysis of its mortgage lending portfolio, resulting in the identification of pricing disparities between protected and non-protected borrowers.

  • Performed model validation services for a large bank regarding its fair lending practices, to review underwriting and pricing models for retail credit, resulting in an assessment and summary of the model’s validity in accordance with the Office of the Comptroller of the Currency (OCC) and the bank’s Model Governance Team Requirements.

  • Conducted an independent review of a large bank regarding its fair lending practices, to assess the fair lending program documentation, evaluate specific operational fair lending control mechanisms, and analyze the fair lending staffing structure, resulting in recommendations for improvement.


B. Scott Fisher
Chief Executive Officer
Kathryn S. Reimann
Senior Managing Director
Carl G. Pry
Managing Director
Mark Westmoreland
Managing Director
Tina M. Shaver
Senior Director II