Representative Engagements
Bank Secrecy Act / Anti-Money Laundering Audits
We conduct Bank Secrecy Act/Anti-Money Laundering (BSA/AML) independent audits for various client segments, following examination guidelines established by the Federal Financial Institutions Examination Council (FFIEC) and the Financial Crimes Enforcement Network (FinCEN). Our independent audits offer management an unbiased assessment of their AML compliance efforts and provide valuable insights into operational and regulatory control improvements. Recommendations from our audits are designed to enhance compliance and operational efficiency, helping our clients stay aligned with the latest BSA/AML regulatory requirements.
Service Type: BSA/AML Independent Audit
Fair Lending Performance Review
Client Type: Intermediate Bank ($1–<$10B)
Service Type: Performance Analysis
Analyzed HMDA data to uncover disparities in decision timing, outcomes, pricing, steering, and geographic lending—supporting fair lending risk management.
Fair Lending Examination Assistance
Client Type: Regional Bank ($10–$50B)
Service Type: Advisory
Post-exam support included redlining analysis and response preparation in coordination with legal counsel, aiding in potential DOJ referral preparedness.
Due Diligence – Residential Mortgage Loans
Client Type: Regional Bank ($10–$50B)
Service Type: Independent Compliance Review
Reviewed hundreds of mortgage loans for regulatory compliance across 34 states, identifying risk levels to guide bulk loan acquisition strategies.
Fair Lending Program Audit
Client Type: Regional Bank ($10–$50B)
Service Type: Program Review / Audit
Conducted a comprehensive audit of the FL CMS, including interviews and risk assessments across marketing, access, and pricing to improve governance and oversight.
CRA Performance Review
Client Type: Intermediate Bank ($1–<$10B)
Service Type: CRA Performance Review
Prepared a full CRA evaluation to support the client’s upcoming examination, assessing performance in lending, service, and investment activities using peer and demographic data.
Compliance Policy and Procedures Development
Client Type: Community Bank | Mortgage Servicer
Service Type: Compliance Consultation
We created or enhanced compliance policies, addressing evolving regulatory expectations and improving governance practices.
CMS Audit for Consumer Finance
Client Type: Consumer Finance – Money Services Business
Service Type: Compliance Audit
We evaluated compliance controls in lending, servicing, and credit bureau reporting, providing actionable recommendations and regulatory enhancements.
Auto Finance Program Review
We conducted a comprehensive review of the auto finance program for a credit union, focusing on various aspects of the auto loan life cycle, including origination and servicing. The review included an evaluation of the credit union’s Compliance Management System (CMS) for detecting and preventing violations of federal regulations applicable to auto loan origination and servicing.
Our review also identified practices that could increase the risk of harm to consumers, aligning with the Consumer Financial Protection Bureau (CFPB) examination procedures, and covering key areas such as:
Credit Union Business Model
CMS Effectiveness
Advertising and Marketing
Application and Origination
Payment Processing, Account Maintenance, and Optional Products
Collections, Debt Restructuring, Repossessions, and Bankruptcy
Customer Complaints and Inquiries
Credit Reporting, Information Sharing, and Privacy
Client Type: Credit Union
Service Type: Independent Compliance Review
Internal Audit Function Development and Co-Sourcing
Faced with continued growth and heightened regulatory scrutiny, a client requested assistance in developing and implementing an internal audit function. We worked closely with the organization to create an audit charter, perform a comprehensive audit risk assessment, and develop a multi-year internal audit plan. Our experienced internal audit consultants executed the audit plan, identifying areas for improvement in the institution’s control environment, policies, procedures, and practices.
Our audits provided practical and sustainable recommendations, addressing root causes of any issues discovered. Beyond completing the audit plan, we also provided ongoing reports to the institution’s Audit Committee and offered continuous consultation as needed to ensure long-term compliance and risk mitigation.
Client Types:
Intermediate Bank – $1–10 billion in assets
Community Bank – <$1 billion in assets
Credit Union
Mortgage Banking – Originator
Mortgage Banking – Servicer
Service Type: Audit Function Development