Independent Validation of NAV Transfer Program Remediation for a U.S. Bank
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February 06, 2026
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One of the world’s largest banks uncovered a systemic problem in its brokerage operations, where excessive fees were charged to a broad segment of brokerage account customers, signaling widespread process and control deficiencies. Despite taking corrective actions and paying restitution to impacted customers, the matter resulted in a regulatory review by the Financial Industry Regulatory Authority (“FINRA”). FTI Consulting served as the independent Third-Party Examiner to provide objective, regulator-ready oversight of the bank’s remediation efforts.
Our Impact:
- Based on FTI Consulting’s evaluation of the existing self‑review processes, the bank was able to confirm that they had accurately identified and remediated all investors eligible to purchase Class A shares under the net asset value (“NAV”) Transfer Programs.
- FINRA adopted FTI Consulting’s independent conclusions and determined that no additional corrective measures were necessary, based upon the thoroughness of our work, which was supported by a full data tracing analysis through every critical system involved in executing the remediation plan.
- Every affected bank customer was accurately notified and remediated, directly contributing to the restoration of the bank’s credibility with customers and regulators, ultimately rebuilding trust.
- The success of this engagement led to additional work with bank’s former senior in‑house lawyer at a national broker-dealer firm that required similar remediations and engaged FTI Consulting based on our credible and cost-effective performance.
Our Role:
- Our team designed and executed a comprehensive review of the bank’s NAV Transfer Programs, assessing the Bank’s remedial processes to determine whether identified issues were fully and appropriately addressed.
- We performed a thorough and independent evaluation of the bank’s remedial processes, including its business procedures and methodologies, as well as the supporting database infrastructure and coding specifications used to identify potentially harmed customers and calculate restitution amounts.
- Our seasoned experts in financial services, data analytics and regulatory compliance independently challenged management assumptions and delivered a comprehensive, evidence-based final report to FINRA that was grounded in documented testing and industry best practices.
Related Information
Published
February 06, 2026
Key Contacts
Senior Managing Director