Mortgage Originations Practice Review

Responding to CFPB Inquiry at a Regional Bank

A regional bank was required to respond to an MRA issued by the CFPB in connection with its mortgage originations practices.
The MRA required the bank to conduct a thorough and independent review of certain mortgage originations for accuracy and compliance with applicable regulations.

FTI Consulting was retained by outside counsel to perform the analysis and due diligence of approximately 4,000 in scope loans in 90 days as required by the MRA.
Developed a comprehensive test plan and automated model to streamline the identification and quantification of potential borrower remediation.
Leveraged existing loan data fields, understanding of loan calculation logic and discussions with bank data teams to extract and further automate the loan level analysis.
Worked closely with the bank and counsel to understand current business processes including the nuances of each loan and confirm findings.
The analysis was conducted using an account review and workflow tool customized for bank requirements including a repository to house relevant analysis from both FTI Consulting and bank SMEs.
Loans were reviewed for the accuracy and timeliness of certain disclosures and supporting documentation.

As the result of FTI Consulting’s analyses, the bank was able to respond to the MRA and remediate all affected borrowers.
The bank leveraged the findings from the review to improve its originations processes, including the internal control environment.