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
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
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.