Consumer Finance and Fair Banking
Strong, scalable and sustainable programs
Fair and Responsible Lending
Recently, regulators have stepped up fair lending enforcement actions. Redlining, reverse redlining, disparate impact pricing, practices that discourage applicants, disparate treatment in loan servicing, new HMDA fields and CRA eligibility are some of the critical risks that require a proactive, practical approach to mitigate and manage. Our Fair Lending experts, many former regulators, offer these benefits:
- A deeper understanding of your risk – We conduct a fair lending risk assessment based on enhanced regulatory expectations and your institution’s size, complexity and business activities.
- Identification and resolution of problematic policies and procedures – We review your current policies and procedures in detail to find potential fair lending problems and recommend ways to prevent them.
- Effective monitoring and reporting – Our experts can prepare you for ongoing enhanced fair lending monitoring and testing based on your risk profile.
- Fair lending reviews – We analyze your data to identify problematic patterns or practices using the latest techniques and tools, such as our proprietary Fair Lending Proxy Analyzer, to detect and remediate issues before the examiners find them.
- HMDA and CRA data validation – We use our LAR Analyzer to perform data integrity reviews for both small and large volume creditors.
- CRA consulting – To provide accurate CRA performance evaluations, we can deliver CRA program architecture, strategic plan development, assessment area delineation support, geocoding and mapping, HMDA/CRA submission and exam preparation/remediation.
Mortgage Lending and Loan Servicing
Now that sufficient production volume has amassed since the sweeping regulatory change over the past two years, examiners are closely examining compliance with the TILA-RESPA Integrated Disclosures (TRID) Rule, or what the CFPB calls “Know Before You Owe.” On the mortgage servicing side, the CFPB’s latest amendments have made the 2014 rules even more detailed and complex. We offer originators and servicers the confidence of knowing their policies, procedures, systems and controls meet all regulatory requirements and industry best practices.
- Pre-TRID – We utilized our proprietary RESPA Settlement Analyzer software solution to review more than 400,000 funded mortgage loans for various clients
- Post-TRID – We deployed our TILA RESPA Settlement Analyzer to provide a post-closing safety net quality assurance review to detect and cure violations. Automated review identifies files requiring further analysis and those that do not, minimizing time-in-file, providing comprehensive root-cause analysis and solving for record retention.
- Download our 160-page TRID Guide to Getting It Right
- Servicing – The increased volume of lending activity has created an unprecedented level of defaulted loans and undercollateralized loan portfolios. We offer comprehensive loan servicing assistance that begins with an applicability matrix to align the relevant laws and regulations to your servicing business. Then, a control environment analysis provides a comprehensive review and possible testing of your institution’s preventative and detective controls across the varied servicing functions. Our proprietary Servicing Analyzer streamlines testing, ties findings to applicable regulations and provides a map of remediation and controls enhancement.
Nonbank Financial Institutions
We are the go-to risk and compliance solution for new, developing or established fintech, marketplace, alternative finance and prepaid access providers seeking expert guidance in navigating the regulatory landscape. We recognize and accentuate the value of establishing cost-effective, self-sustaining, risk-based compliance management systems for successful partnering relationships with respected banks, service providers, investors and retailers, as well as ensuring product offerings and operations comply fully with CFPB guidelines, partner bank standards and applicable compliance regulations.
- Payday lending – Superior compliance consulting for finance companies and check cashers offering small-dollar short-term credit in the form of payday loans, cash advance loans, auto title loans and check advance loans.
- Card products – Proven compliance support focused on credit, debit and prepaid card products for all institution types, including nonbank providers of prepaid access and prepaid program managers.
- Fintech/marketplace lending – We provide CMS architecture and implementation for all manner of nonbank lenders, fintech companies and banks entering strategic relationships with such entities, e.g., P2P and POS lenders, and others using customer-facing digital lending technologies.
- Vehicle finance – We provide unparalleled risk and compliance support for all institution types related to vehicle finance products and services, including direct and indirect lending, consumer leasing, and collections and recovery.
Communications and Training
For all risk and compliance solutions described above, Capco also provides communications support, custom online and instructor-led training, curriculum consulting and management reporting.