Compliance

CRMa delivers forward-looking compliance solutions custom-fit to your unique compliance needs. Our strictly in-house experts are on-hand to ensure above-market standards, consistency, and in-depth consultation and collaboration across all areas of compliance reviews.

Compliance Solution Features:

  • Top-down, consultative approach to your entire range of compliance related risks and needs
  • Probative identification and quantification of compliance needs and custom-fit solutions
  • Best-in-market expertise that combines practical experience in banking and depository-compliance issues — consultative service and best-practice scenarios for risk mitigation and management
  • Rigorous identification and discussion of potential regulatory issues related to management, documentation and macro-level needs
  • Comprehensive review process to develop and fine-tune corporate-wide compliance culture

CRMa is at the forefront of evolving regulatory and compliance practices and poised to advance your compliance and documentation offerings.

Product Descriptions

Fair & Responsible Lending, Unfair, Deceptive & Abusive Act & Practices (UDAAP)
  • Analyze Home Mortgage Disclosure Act (HMDA) data for adverse patterns and obvious, technical-compliance and data errors
  • Populate HMDA loans with DTI, LTV, CBI (based on criteria selection). Review specific files for denied loans with positive underwriting identifiers and originated loans with negative underwriting identifiers for potential discriminatory factors
  • Review underwriting of select loan applications for adherence to and consistency with multiple variables: excluding debts, grossing up income, treatment of medical collections, documentation requirements for disability income, etc.
  • Pricing review for unsecured loans
  • Spousal signature review based on targeted sample of guarantors with a common last name and a first name of male and female
Federal Regulatory Loan Compliance Review
  • Compliance review based on significant federal regulations such as Equal Credit Opportunity Act (ECOA), HMDA, Flood, Real Estate Settlement Procedures Act (RESPA), Truth-in-Lending, Fair and Accurate Credit Transactions Act, Service members Civil Relief Act, (UDAAP), etc.
Federal Regulatory Deposit Compliance Review
  • Compliance review based on significant federal regulations such as Truth in Savings, Expedited Funds Availability, Electronic Funds, Privacy, Marketing, Unlawful Internet Gambling Act, etc. Focus of review is to determine systemic issues, effectiveness of review process, and root cause of errors
Bank Secrecy Act (BSA) Third Party Review
Our review covers core procedures of the FFIEC guidelines used by regulatory agencies. However, if we uncover potential for increased risk, we engage our staff and expertise to expand our scope and incorporate additional procedures to further mitigate your risk.

  • Review performed in compliance with the FFIEC BSA/Anti-Monetary Laundering Guidelines
  • Written Review Program includes:
    • Scope
    • Prior exam comments
    • Board oversight & BSA qualifications – assess management and board engagement and training in BSA related regulations and issues
    • BSA policy, program and procedures
      • Assess the adequacy of your BSA/AML compliance program
      • Determine whether you have developed, administered and maintained an effective program for compliance with the BSA and all of its implementing regulations
      • Ensure that your practices correspond with written policies
    • Risk assessment – We review your internal risk assessment of products and services to ascertain that risks have been appropriately identified and addressed across all products and services
    • Transaction testing – Our testing includes customer identification, currency transaction reports, suspicious activity reports, money service businesses, phase I and phase II CTR exemptions, monetary instruments, wire transfers, and information sharing requests. Appropriate risk-based transaction testing verifies adherence to BSA recordkeeping and reporting requirements
    • Office of Foreign Assets Control (OFAC) – We assess your risk-based, Office of Foreign Assets Control (OFAC) compliance program for appropriateness to your OFAC risk. Evaluations factor products, services, customers, entities, transactions, and geographic locations
    • Monitoring
    • Training – We review and evaluate training methods, frequency and documentation for each employee, manager and board member to determine adherence with applicable regulations and guidelines.
Mortgage Services Review
  • Third-party contracts
  • Inquiry vs. application
  • Pre-qualifications / pre-approvals
  • Regulatory disclosures
  • HMDA data collection and reporting
  • Mortgage originator compensation
  • Advertising for UDAAP issues
  • Evidence of steering, redlining, or other obvious discriminatory factors
  • Treatment of credit scores (highest, lowest, medium of borrower and/or co-borrower)
HMDA Review
  • Technical compliance with Home Mortgage Disclosure Act, reconciling HDMA LAR data with source documents
  • Review management reports of potential loans subject to HMDA, based on purpose and/or collateral with reconcilement to HMDA Loan Application Register
Loan Operations Review
  • Review servicing of loan portfolio to include "loans-in-process" account reconcilement, monitoring and force placement of flood insurance, as applicable, negotiable collateral, exception reporting, paid note and collateral release process, etc.
Fair and Responsible Lending Training for Board Directors
  • Current fair lending issues including recent litigation and/or regulatory exam criticism.
  • Trends in fair lending enforcement and culture of compliance.
Regulatory Compliance Training
  • Always include Fair and Responsible Lending and UDAAP regardless of subject
  • Current regulator issues
  • Recent regulatory changes
  • Specific topics requested