Profile

Monitorship

Performing biennial assessments of a software and identity theft protection organization’s Information Security Program pursuant to the terms of the Stipulated Order entered into with the Federal Trade Commission.  We are evaluating the design and effectiveness of business processes and internal controls implemented to enhance protection of the security, confidentiality, and integrity of personal information, and integrity of personal information collected from or about consumers.

Evaluated compliance of a money service business with the requirements of the Stipulated Order entered into with the Federal Trade Commission as the Independent Compliance Monitor.  Assessed business processes and internal controls implemented or enhanced to comply with the terms of the Stipulated Order.  Additionally, assessed the IT general controls over the applicable systems to ensure completeness and accuracy of data utilized in our evaluation of compliance with the terms of the Stipulated Order.

Assisted the monitor, appointed by the Office of Mortgage Settlement Oversight, in evaluating three large financial institutions, including one of the big four national banks, with their compliance with the terms of the National Mortgage Settlement.  Confirmed servicing of defaulted mortgage loans and related foreclosure actions were performed in accordance with the National Servicing Standards implemented as part of the Consent Judgment.

Assisted the Federal Deposit Insurance Corporation (FDIC) in evaluating compliance with the terms of shared-loss agreements entered into by 25 acquiring financial institutions covering over 288,000 loans totaling over $50 billion in unpaid principal balance. Worked with the FDIC to develop procedures to evaluate loss and eligible expense claims related to loans covered under the shared-loss agreements.

Compliance and diligence services

Assisting a financial services organization evaluate a compliance plan required under a Consent Order entered into with the Consumer Financial Protection Bureau.  We are working with the organization in assessing the design and effectiveness of business processes and internal controls implemented to correct violations of the Electronic Fund Transfer Act, Consumer Financial Protection Act, and inadequate error resolution investigations.

Evaluated one of the largest debt collector’s plan to redress consumers pursuant to the terms of the Consent Order entered into with the Consumer Financial Protection Bureau. Developed with the organization procedures performed in validating the Redress Plan is consistent with the requirements of the Consent Order.

Assisted a global pharmaceutical and consumer product manufacturer with response to DOJ enforcement inquiry by performing comprehensive risk-based assessment of client’s anti-bribery and anti-corruption compliance program.  The assessment resulted in the development of a roadmap with actionable implementation plan to remediate program gaps, strengthen controls and thereby enhance overall compliance program.

Assisted a consumer product wholesaler with response to a multi-million dollar OFAC trade sanction enforcement action by performing comprehensive compliance gap assessment under the direction of external legal counsel. The assessment resulted in the identification of multiple additional compliance gaps that were effectively remediated prior to the identification of additional potential violation.

Assisted a global pharmaceutical and consumer product manufacturer with pre-acquisition anti-corruption and anti-bribery due diligence services.