Mortgage Originations Practice Review
Responding to CFPB Inquiry at a Regional Bank
April 13, 2023
- 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.