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Services

  • 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
  • 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

Representative Engagements

  • 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
  • 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 Advisory
    • Mortgage Origination, Servicing, and Secondary Marketing Operational and Compliance Risk Assessments
    • 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
    • Training
    • Technology Usage
  • 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)
  • 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
  • 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

  • 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

  • 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
  • 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