Regulatory compliance consulting

Regulators expect financial institutions to have an effective Compliance Management System, which includes Board and Management Oversight, Compliance Program, and Service Provider Oversight, that is adapted to its business strategy and operations. We offer services and solutions to assist institutions get to the right size and shape of a compliance management system, while considering people, process, and technology, to remain compliant and avoid major fines and reputational risk. Our financial services professionals help financial institutions to implement and enhance their compliance management systems based on industry-leading practices.

Compliance failures can be costly, resulting in litigation, financial penalties, regulatory constraints and reputational damage. What you don’t know may hurt your organization. Our subject matter specialists help financial institutions conduct compliance assessments and testing to proactively identify and address compliance issues to remediate consumer harm and prevent scrutiny from regulators. Our proven methodologies for compliance testing include assessments of all products and services offered by financial institutions, through each stage of the product lifecycle, for line-by-line alignment with regulatory requirements. 

We are experienced in conducting compliance testing for all key banking laws and regulations, including the Equal Credit Opportunity Act (ECOA) / Regulation B, the Fair Credit Reporting Act (FCRA) /  Regulations V and FF, the Fair Debt Collection Practices Act (FDCPA) / Regulation F, the Flood Disaster Protection Act (FDPA), the Servicemembers Civil Relief Act (SCRA), the Real Estate Settlement Procedures Act (RESPA) / Regulation X, the Truth in Lending Act (TILA) /  Regulation Z, the Electronic Fund Transfer Act (EFTA) / Regulation E, the Expedited Funds Availability Act (EFAA) / Regulation CC, and the Truth in Savings Act (TISA) / Regulation DD.

A strong customer complaint management program is essential to a successful Compliance Management System. We provide solutions to develop or enhance financial institutions’ complaint management program, including conducting lookback analyses on how complaints were handled and assessment of the institution’s entire complaints management framework. Through the combination of our experienced professionals in our regulatory compliance consulting and data analytics practices, we can also help you to conduct a thorough analysis of your complaints data to identify key risks and concerns that warrant attention.

An effective third-party risk management program mitigates risk, promotes compliance with regulatory requirements, and improves performance across those relationships, including relationships with financial technology-focused entities such as bank/fintech sponsorship arrangements. We assist financial institutions in managing all phases of their third-party relationships, from planning to termination, to minimize compliance risk and avoid consumer harm. Our end-to-end third-party risk management services can help your institution to identify compliance concerns in existing third-party relationships and evaluate new potential relationships prior to contracting.

The regulatory landscape continues to be complex and dynamic. Proper and timely training for bank personnel can reduce risk and prevent regulatory violations and potential consumer harm. We understand the regulatory environment facing financial institutions across all products and services. We offer a customized approach to building and providing a risk-based training program that best suits the size and complexity of an institution.

Regulatory requirements applicable to the financial services industry are rapidly increasing in volume and complexity. Financial institutions must ascertain that their controls adequately consider all applicable laws and regulations. Our regulatory mapping services help build your institution’s regulatory library by identifying and documenting rules, laws and regulations applicable to your institution. Our professionals can assess your inventory of regulatory requirements and chart applicable requirements to specific entities, products, services, processes, controls and procedures to identify and remediate gaps in how you are managing regulatory risk.

Addressing regulatory issues is undoubtedly complex and requires careful consideration, a clear approach and methodology. We assist financial institutions in remediating concerns identified by regulators, including Consent Orders and Matters Requiring Attention. Our regulatory compliance professionals collaborate with financial services institutions to develop a thorough and timely response plan to address regulatory concerns, execute steps to remediate issues and validate the resolution of issues. We also help remediate consumer harm and develop effective frameworks to help you confidently manage the risks associated with these processes.

Ever-evolving regulatory expectations have forced financial institutions to examine their lending and banking practices to confirm they are fair, transparent, and competitive. As regulators have indicated their renewed focus on addressing discriminatory practices in underwriting, lending and other aspects of financial services, it is important to verify that business decisions made by the institution are impartial and unbiased. We assist financial institutions in identifying and remediating Fair Lending and Fair Banking concerns within their business practices through governance assessments, review of policies and procedures, Fair Lending/Banking data analytics and comparative file reviews.

Our regulatory compliance consultants are comprised of knowledgeable professionals who have direct, hands-on experience identifying and mitigating UDAAP risks. We consider risks of consumer harm along each stage of a financial product’s lifecycle, and for each stakeholder involved. We provide the requisite industry-leading insight and regulatory knowledge that can help your institution identify and address UDAAP risks in your business processes and practices. In addition, our team can help you develop and implement a compliance program best suited to the size and complexity of your institution to effectively mitigate UDAAP risks.  

Bank regulators are placing greater emphasis on assessment activities related to the imposition of overdraft and NSF fees by financial institutions during examinations. Specifically, regulators have voiced concerns around overdraft fees on transactions that were authorized against a positive balance but settled against a negative balance (“APSN”) and multiple NSF fees for the same transaction represented for payment against an insufficient balance. Our professionals are experienced in assessing overdraft and NSF fees charged by financial institutions, including disclosure reviews, system logic assessments and transaction testing, to remediate consumer harm and to reduce scrutiny from regulators.

Regulators are escalating their scrutiny of lender data integrity, and under new regulations, the volume of reportable data is expanding dramatically. As with any significant change, having the proper people, processes and systems and taking proactive measures to ascertain compliance are key components in the successful execution of any Compliance Management System. We work with lenders to analyze and review data accuracy and integrity for compliance with regulatory requirements. We can scale data integrity engagements for any challenge to meet stringent deadlines, such as annual and quarterly reporting.

Having a strong Community Reinvestment Act (CRA) program remains an important consideration for depository institutions. Recent trends recognize that CRA lending and investment is not solely a compliance function but should be recognized as a line of business that seeks to responsively and innovatively address community credit needs while maintaining safety and soundness. We help institutions of all sizes develop, evaluate, enhance or implement CRA programs that meet the ever-changing expectations from regulators, including the ongoing CRA Modernization efforts.

Loan products are traditionally the largest segment of a financial institution’s balance sheet. Institutions must closely monitor the loan portfolio to ascertain that management is aware of the potential impact of these assets on the institution’s income statement and balance sheet. Failure to properly review credits and their risk ratings can draw scrutiny from regulators and impair an institution’s earnings and capital ratio. Grant Thornton professionals are experienced in conducting independent loan and credit risk reviews to help financial institutions enhance their loan quality review processes and credit portfolio risk management programs.

The Current Expected Credit Loss (CECL) methodology requires financial institutions to forecast losses over the life of the portfolio utilizing lifetime historic charge-off data. We offer a customized approach to help institutions develop, enhance, implement and review their CECL calculations to ascertain that the institution’s accounting methodologies meet the standards set forth by the Financial Accounting Standards Board (FASB).

Liquidity reflects an institution’s ability to fund assets and meet current and contingent obligations through cash, liquid assets and potential borrowing lines. Regulatory capital requirements keep institutions solvent and keep the entire financial system safe and sound. Asset liability management provides important management oversight for interest rate risk and liquidity risks at the institution. We offer a customized approach to the development, implementation and review of capital, liquidity, and asset liability management programs that best suit the complexities of our clients.

A Resolution Plan (also known as a “Living Will”) identifies triggers and options for responding to a wide range of severe internal and external stress scenarios to restore a covered bank to financial strength and viability in a timely manner. During their tenure at the FDIC, the professionals in our Regulatory Center of Excellence were involved in developing sections of Dodd-Frank (Title I and Title II) and the resolution of numerous banks. We are experienced in helping financial institutions develop and enhance their Resolution Plans through identifying and capturing of systemic impact risk strategies, restoration options and governance processes that would allow for rapid and orderly resolution in the event of unrecoverable financial distress or bank failure.