Mortgage Compliance Services
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Mortgage Compliance Services

Representative Engagements

Promontory is the leading mortgage compliance review firm, having conducted more testing of compliance with federal, state, and agency servicing standards than any other firm. In addition, Promontory has advised leading servicers on mortgage compliance with new national servicing standards.

 

The Promontory approach grows directly from a combination of public- and private-sector expertise: we work with the world’s leading companies to identify, evaluate, and resolve issues of actual or potential concern to their regulators. We also work with regulatory agencies to advance and enhance their own supervisory agendas.

Promontory has conducted hundreds of engagements with banks, mortgage companies, servicers, broker-dealers, insurance companies, GSEs, rating agencies, and others. Our informed perspective on matters of greatest importance to regulators allows us to provide clients with strategic and practical insights they can use.

Experience and Expertise

Promontory’s management team and staff include former regulators with unmatched regulatory and operational expertise in mortgage servicing and related compliance areas. Our professionals and advisers have previously served in senior policymaking and policy-implementing roles around the world, including:

  • Office of the Comptroller of the Currency
  • Consumer Financial Protection Bureau
  • U.S. Department of the Treasury
  • Financial Services Oversight Committee
  • Federal Deposit Insurance Corporation
  • Securities and Exchange Commission
  • Federal Reserve Board
  • U.S. Congress

Our Services

Compliance Policy and Procedure Reviews

Promontory reviews company policies and procedures against regulatory requirements, expectations, and the leading industry practice to identify gaps and opportunities for enhancement. Promontory can also work with your company to revise the gaps.

Due Diligence and Forensic File Reviews

Promontory creates customized file review solutions. From targeted statistical sampling through 100% review, we implement portfolio due diligence and evaluate compliance for a wide range of regulatory and project management needs. We have developed proprietary case-management tools that offer practical and robust compliance solutions and use real-time quality metrics to track and report on high-risk areas.

Promontory has conducted forensic reviews of a wide range of control lapses, including:

  • Rogue trading
  • Mortgage foreclosure compliance
  • Anti-money laundering
  • Sanctions

We advise and assist management teams in preparing plans, performing risk assessments, and revising policies to comply fully with enforcement orders in a way that is both practicable and ensures that our clients meet regulatory expectations the first time.

CFPB Examination Preparedness

The CFPB examination process for banks and nonbanks, including mortgage companies, is fully in place. Promontory conducts comprehensive CFPB examination preparations that typically last 30 days and help institutions prepare for these examinations.

Imminent Foreclosure Reviews

Regulators are now emphasizing reviews of loans in imminent foreclosure. Promontory understands that this is an area of high risk, and that regulators such as the OCC may soon be expanding their review requirements to include all servicers. 

As a supplementary layer of oversight, Promontory supplies templates and checklists to ensure compliance on every front of the imminent foreclosure review process. Promontory also provides training solutions and resources to perform a review of imminent foreclosure files, either on-site or off-site.

SCRA Compliance Reviews

Promontory has a dedicated team of compliance experts who possess up-to-the-minute knowledge of the nuances of the Servicemembers Civil Relief Act (SCRA) and have working relationships with institutions that oversee SCRA enforcement.

Promontory understands that this is an area of high risk, and that regulators such as the OCC may soon be expanding their enforcement and oversight actions. In this highly publicized arena, Promontory can help companies remain at the forefront of SCRA compliance.

Outsourced Compliance Resources

With experienced compliance testing resources in strategic locations nationwide, Promontory can provide a compliance team equipped to immediately begin building effective policies, procedures, and training programs for permanent employees in expanding compliance departments. Our resources can provide instant staffing solutions or project management guidance.

Our ongoing quality-control services provide cost-effective reviews through two main methods:

  • We monitor data for statistical anomalies that indicate a greater-than-normal likelihood of non-compliance. Promontory’s experience reviewing thousands of mortgages for compliance breaches has led us to develop finely tuned algorithms that identify the greatest risk files. When the algorithms generate an alert, we subject the file to a full review against the compliance requirements that produced the alert.
  • We review files on a sampling basis against a set of tests, which are developed in conjunction with the client, or specified by the client. 

Representative Engagements

  • Promontory assisted several bank and nonbank financial institutions in preparing for and managing CFPB exams, and in working with the CFPB and other authorities regarding appropriate remediation.
  • Promontory is currently conducting mortgage servicing and default risk management compliance reviews at four of the largest mortgage servicers in the U.S., each of which is subject to public regulatory enforcement actions. These reviews include evaluating the effectiveness of the organization and execution of enterprise-wide compliance programs and processes.
  • Promontory assisted several financial institutions in establishing a compliance and risk-management framework consistent with industry-leading practices and regulatory expectations.
  • Promontory conducted preparedness reviews (safety and soundness, risk management, and compliance) for several thrifts and thrift holding companies not previously subject to OCC and FRB supervision. Implementation of Promontory’s recommendations mitigated supervisory concerns and helped avoid and ease supervisory actions, including enforcement.
  • Promontory assisted financial institutions in developing a consumer protection compliance-risk framework and implementation plan, based on a detailed assessment profile and industry best practices. Promontory then worked with the banks to develop specific tools that they continue to use in their enhanced compliance programs.
  • Promontory assisted nonbank financial institutions in developing a self-assessment program and in successfully presenting that program to the CFPB.