FAIR CREDIT REPORTING ACT / METRO 2 CREDIT ... - …/media/www/site/downloads/financial... · services and tools. fair credit reporting act / metro 2 ® credit reporting

SERVICES AND TOOLS

FAIR CREDIT REPORTING ACT /METRO 2® CREDIT REPORTING

2

TABLE OF CONTENTS

Navigant Approach and Tools

Representative Engagements

Current State of the Industry01

02

03

04 Select Management Bios

SECTION ICURRENT STATE OF THE INDUSTRY

4 Proprietary & Confidential

Many industry participants do not yet have well developed infrastructure and expertise to cope with the current regulatory environment. Most are aware of the need to change.

Num

ber o

f Firm

s

Maturity of Furnishing Practices

Least Mature Most Mature Mature

Number of firms at Maturity Level

Majority

Complete checks on population with monthly reporting tools and dashboards

Full independent validation Full documentation on end to

end processes Minimal inconsistencies in

Metro 2 Transmission

Lack of data governance checks or tools

No independent validation Limited documentation on end

to end processes Widespread inconsistencies in

Metro 2 Transmission

Limited assessment of any missing fields or invalid values

Limited independent validation

Documentation for some aspects of key processes

Some inconsistencies in Metro 2 Transmission

CURRENT STATE OF THE INDUSTRYFCRA / METRO 2 COMPLIANCE MATURITY


Flurish, Inc. (doing business as LendUp) – September 27, 2016• $1,800,000 civil penalty along with $1,830,000 in refunds to 50,000 consumers for failing to deliver on product promises, improperly

furnishing information to the credit reporting companies, and failing to have written policies and procedures regarding furnishing consumer information to credit reporting agencies.

Wells Fargo – August 22, 2016• $3,600,000 civil penalty in addition to $410,000 refund of late fees for misapplying borrower payments, misleading borrowers, illegal

late fees, and failing to correct inaccurate borrower information furnished to consumer reporting agencies

CarHop – December 17, 2015• $6,465,000 civil penalty for impacting 84,000 accounts ($75+ per account), Independent Consultant required to do a review of policies,

procedures, practices, and systems

Clarity Services, Inc. – December 3, 2015• $8,000,000 civil penalty for illegal credit reporting practices and improper dispute investigation procedures

General Information Services Inc/e-Backgroundchecks.com – October 29, 2015• $10,500,000 to relieve harmed consumers by providing inaccurate credit information to potential employers, in addition to a $2,500,000

civil penalty, Independent Consultant required to review furnishing policies, procedures and practices

DriveTime – November 19, 2014• $8,000,000 civil penalty, Independent Consultant required to review furnishing policies, procedures and practices

Independent Consultants are paid for by Company, adding to cost of Consent Order

CURRENT STATE OF THE INDUSTRYREGULATORY FOCUS – CFPB CONSENT ORDERS

Remarks from the CFPB Director Richard Cordray (bold emphasis added)February 3, 2016Today we are issuing a bulletin warning banks and credit unions that they must meet their legal obligation to have appropriate systems in place with respect to accuracy when they report information, such as negative account histories, to the consumer reporting companies. More effort and rigor are needed to make sure that the risks consumers actually pose to potential financial providers can be evaluated correctly.

CFPB Consent Orders


Private Action1

No private right of action for accuracy, but;

Private right of action for failure to conduct a reasonable investigation of an indirect dispute: Actual Damages, costs and attorney’s fees Civil Penalties of $100 - $1,000

Federal Enforcement (CFPB)2

Regulatory agencies, including the CFPB, can bring

enforcement action under the Consumer Financial Protection Act for violations of a federal

consumer law (including Credit Reporting)

Penalty Amounts (12 U.S. Code § 5565):

Any violation (i.e. including unintentional ones) up to $5,000 per day

Recklessly engages in a violation up to $25,000 per day

Knowingly violates a Federal consumer law up to $1,000,000 per day

Mitigating factors include the gravity of the violation, the losses to consumers, and the history of previous violations

The penalties and consequences of non compliance can be severe.

CURRENT STATE OF THE INDUSTRYFINES AND PENALTIES FOR NON COMPLIANCE


Navigant has developed a proven approach to evaluate and identify issues related to the integrity and accuracy of data furnished to the Credit Reporting Agencies (“CRAs”). Navigant leverages numerous tools to improve FCRA compliance.

Data lacks consistency from input to output i.e., inappropriate values in fields, position of fields using incorrect record layout

Inaccurate demographic information such as, Dummy SSN, Inaccurate DOB, Zip Codes, etc.

Lack of information in general, sparse data inputs into the Metro 2 processing

Garbage In Garbage Out

Incorrect information in one field can have cascading effect on other fields

Data Quality

Incorrect or inadequate Metro 2 / Business Requirements Documentation

Misunderstanding of Business Definitions e.g. Interest Due, Date Opened, Date Closed, Deferred Payment Start Date

Delinquency for Metro 2 purposes may be calculated differently than for day to day business and collection activity

Even the Credit Reporting Resource Guide can provide conflicting information or items that may conflict with other areas of law

Metro 2 Interpretation

Incorrect calculation of fields, e.g. ensuring that fees and interest are appropriately reflected in Current Balance but do not include future charges

Failure to develop and document appropriate hierarchies, e.g. for Account Status where an account is delinquent and charged off and repossession has taken place or for Special Comment Codes

Timing issues such as when the transmission is generated and how reversed payments are addressed

Programming Error

Issues when furnishing often manifest in the following four areas:

CURRENT STATE OF THE INDUSTRYCOMMON INDUSTRY GAPS

Lack of formalized IT/Technical documentation for Metro 2 file generation

Procedures are outdated and reference older versions of Metro 2 guidance using incorrect codes

Process maps do not adequately reflect what is taking place and are lacking risk and control points

Failure to document key concepts such as the organization’s definition of a reasonable investigation or a frivolous dispute

Poor Documentation


CURRENT STATE OF THE INDUSTRYCOMMON PITFALLS AND MISTAKES

Not reporting charge off amount for charged off accounts Not reporting a DOFD for accounts with a delinquent / derogatory status Populating Payment Rating for account statuses that are supposed to be blank filled Invalid Portfolio and Account Type combinations Paid in full loans with Current Balances Not changing Scheduled Monthly Payment to zero once account charged off

Illogical Conditions

Including interest/finance charges in Original Loan Amount Not including fees and/or interest due in current Balance Rounding rather than truncating values Using end of month for Date Closed Counting delinquency immediately rather than 30 days after the bill due date Using billing date for Date of Account Information Using charge off date as DOFD Only reporting last payment amount not summing all payments in reporting period Payment History Profile not being updated e.g. for retroactive deferrals

Placing businesses in base segment Placeholders (999999999, 1234, etc.) for social security numbers Furnishing accounts with insufficient information after a transfer, e.g. unknown DOFD Including amounts not 30 days past due in Amount Past Due field

Zeroing out Current Balance Not reporting Dates of Last Payment Incorrect Consumer Information Indicators Incorrect Payment History Profile (e.g. D between petition date and resolution) Not reporting a DOFD when a borrower in J1/J2 has a CII but borrower in base does not Reporting a DOFD for post petition bankruptcy debt

Continuing to report closed accounts Continuing to report deceased borrowers Using deletions too frequently/inappropriately Failure to distinguish between voluntary/involuntary surrender ‘Re-Pollution’ of accounts corrected via eOSCAR after dispute Use of AI Special Comment Code potentially impacting SCRA Not using code for foreign addresses (may not create tradelines) Failure to apply Compliance Condition Codes to accounts with direct disputes

Calculation Errors

Data Quality

Bankruptcy

Others

SECTION IINAVIGANT APPROACH AND TOOLS


An evaluation of the accuracy of the Metro 2 furnishing file (for each

business unit and or system)

In depth review of a sample of accounts tracing information

throughout the furnishing process

Customized dashboards highlighting Key Risk Indicators for FCRA activities such as Furnishing and Disputes

Current state assessment of corporate and business unit policies and procedures

NAVIGANT APPROACHCORE SOLUTIONS

While Navigant develops customized solutions for our clients depending upon their individual needs and unique circumstances, we often cover four core areas:

While Navigant has had success performing all of the solutions above, clients can select key activities most applicable to their situation. For example, a review of dispute related policies and procedures with tradeline

testing of bankruptcy and charge off accounts.

Navigant – Value in Tailored Solutions

Metro 2 File

Analysis

Tradeline Testing

1

4 KRIDashboards

2

3

P&P Review / Walkthroughs


NAVIGANT APPROACHSELECTED SERVICE OFFERINGS

Policy & Procedure Review / Walkthroughs

Evaluation of Metro 2 File Tradeline Testing KRI Dashboards

Leverage previously identified process and controls work (i.e. internal assessments, internal audit reports and quality assurance testing)

Review Policies & Procedures for compliance with FCRA and Regulation V, 12 CFR 1022.42 § andAppendix E

Evaluate controls via interviews with business units and compliance and review process maps when available

Observe the direct and indirect dispute resolution process, response timeliness, tracking and reporting. Verify data supports dispute resolution

Evaluate staffing resources supporting credit reporting, including disputes

Review training related furnishing material for eOSCAR, furnishing / submission systems, other CRA tools (if applicable)

Gap analysis of file evaluating: Appropriate segments

submitted All required fields submitted Correct record layout used Recommended remediation

(if applicable)Deploy over 150 different

tests to assess Metro 2 File

Metro 2 logic test examples Delinquent accounts have a

date of first delinquency, amount past due etc.

Account status and special comment code combinations

Business rules based on industry and asset class Terms duration less than 30

years for mortgages, 7 years for auto, 20 years for student loans, etc.

Loan dollar amounts match portfolio expectations

Delinquency, bankruptcy,dispute and deceased accounts match management reporting

Sample at least 30 tradelines per system/portfolio and perform four way matching between servicing system, Metro 2 file, CRA soft inquiry reports

Tradelines sampled to cover scenarios such as: Bankruptcy Repossession/foreclosure Charge offs Fraud and Disputes Delinquency/DOFD

Calculation Confirm accuracy of data

and mapping programs used to create Metro 2 files

Product specific analysis taking into nuances across industry and account type

Provide root cause analysis Isolated Data Integrity Issue Systemic Data Integrity

Issue Systemic Software Issue CRA Handling

Establish key risk indicators and metrics specific to the industry, portfolio and business process

Executive level heat maps identifying key risk areas e.g.dispute response timelines

Enables continuous monitoring of credit reporting activities including dispute handling and furnishing data quality

Direct and Indirect Dispute Metric examples:

# of Disputes per FTE Average time per dispute % Disputes pending for

over “x” days

Furnishing Metric examples:

% Account Suppressed # of accounts neither

suppressed nor furnished % of Warnings per

furnished accounts % of Rejects per furnished

accounts

1 2 3 4


• Policy and Procedure Review / Walkthroughs - Gap analysis to determine areas of risk within controls framework. Interview key stakeholders and document the current status of policies, procedures and controls pertaining to FCRA

and furnishing of consumer data to the CRA’s Review policies for compliance to § 1022.41 and § 1022.42 Review procedures for compliance to policies and regulations Map existing documentation to 12 CFR 1022 Appendix E, which governs interagency guidelines concerning the

accuracy and integrity of information furnished to consumer reporting agencies Assess how direct and indirect disputes are investigated, tracked and resolved Create Risk Ranked Gaps Matrix (example below) Provide recommendations for remediation, include best in class targets

1

NAVIGANT APPROACHPOLICY AND PROCEDURE REVIEW / WALKTHROUGHS

No Gap

N/A

High Risk Gap

Medium Risk GapLow Risk

Gap

Key

A B C D E F G H I J K L M

POLICY Fair Credit Reporting Act

POLICY Vendor Management

PROCEDURE Amend Consumer Credit File

PROCEDURE AUD

PROCEDURE Bankruptcy

PROCEDURE Cease and desist

PROCEDURE Charge Off

PROCEDURE Credit Dispute via Call

PROCEDURE Credit Dispute via Letter

PROCEDURE eOSCAR

PROCEDURE Fraud and ID Theft

PROCEDURE ID Theft Affidavit and Instructions

PROCEDURE Indirect Disputes

PROCEDURE Metro 2 File Creation

PROCEDURE Quality Assurance

PROCEDURE Reject Reports

12 CFR 1022 Appendix E, Part III Items

Polic

ies

Document

Proc

edur

es


Metro 2 File Analytics & Risk Ratings - database/analytics to evaluate actual Metro 2 files. Tool does the following: Performs Data Analytics

Identifies where applicable max, min, counts, and standard deviation of fields Performs frequency/stratification and bucketing of all fields into risk buckets including

• Balance ranges to identify unusual values (e.g.. for loans with large balances or negative balances)• Date Ranges (identify dates which may not be logical)• Missing Values • Account Status counts

Utilizes smart logic/business rules comparing fields to identify furnishes results which may be inaccurate • Account Status / Date of first delinquency • Provides loan level exception reporting based on business rules for audit/review

Provides automated summary reporting of analysis Identifies incorrect record layout, missing segments and/or missing fields

2

NAVIGANT APPROACHEVALUATION OF METRO 2 FILE


Servicing System to Metro 2 File to CRA soft pull - Approach and template to facilitate testing of the accuracy of Metro 2 calculations used to create Metro 2 file. The template provides a landing spot to process source servicing data to perform independent calculation for conversion to Metro 2 format. Additional comparison to CRA outputs. Items include:

Clear methodology to ensure all unique and high risk Metro 2 calculations are tested

Manual or bulk recalculation of Metro 2 fields using source servicing system information

Input entry screen for CRA soft pulls to validate reporting agencies are receiving and processing data properly

Audit Reporting / Tracking of calculation comparison results across all segments/fields

Root cause analysis of any potential issues

3

NAVIGANT APPROACHTRADELINE TESTING


NAVIGANT APPROACHEXECUTIVE REPORTING AND KRI DASHBOARDS

Executive Dashboard and KRI Reporting - Key metrics for management to monitor Credit Reporting metrics and focus on high risk areas using a customized dashboard Design an Executive Reporting Dashboard to facilitate FCRA monitoring of key disputes and furnishings metrics across

various product lines

Establish tolerance thresholds for each risk indicator based on industry standards, regulations and data analysis

Perform continuous surveillance of business activities through data collection and analysis

Ensure compliance with FCRA timelines and the accuracy and integrity of furnishing data

Identify potential risks in the overall credit reporting process

Direct and Indirect Dispute Metrics: % of Disputes # of Disputes per FTE Average time per dispute % Disputes pending for over “x” days % Modified account disputes % Disputes QA’d System Change Requests Pending Regulatory Pronouncements

Furnishing Metrics: % Account Suppressed # of accounts neither suppressed nor furnished % of Warnings per furnished accounts % of Rejects per furnished accounts # of accounts QA'd % of QA'd accounts with findings % of accounts with key Metro 2 field issues

4


Rejection Analytics Example Disputes Analytics Example

CRA Submission / Rejection Analytics - Database/analytics which takes rejection files from each of the CRAs to perform analysis and dashboard reporting. Used to identify and isolate submission errors, allows for review and development of solutions.

Disputes Analysis – Analytics tool to evaluate and identify issues associated with borrower disputes. Tool has database which reads in as input e-OSCAR indirect dispute file and client tracking of direct disputes.

NAVIGANT APPROACHOTHER TOOLS


NAVIGANT APPROACHOTHER SERVICES

Assist in the SDLC process for system changes or upgrades that impact FCRA or the creation of furnishing file - Tasks can include developing business requirements, reviewing solution design documentation, source to target mapping, creation of use cases, assessing test plans and performing User Acceptance Testing to verify that the changes to the credit reporting system functionality have been updated appropriately based on business requirements.

Business Requirements / Solution Design and Source to Target Mapping

• Develop use cases to address various scenarios e.g. bankruptcy, payment application, returns, total loss, repossession/foreclosures, charge offs, 1099-Cs etc.

• Review test plans for completeness. Assess test coverage and traceability matrices.

• Conduct pre-production testing to evaluate the completeness and accuracy of each field in the test Metro 2 file prior to implementation‐ Deploy data analytics tool‐ Perform tradeline testing

• Assist with coordination of testing with CRAs

• Apply formal defect management process

Use cases, test plan assessment and pre-production testing

Implement On-going Quality Control

• Leverage processes from data analytics and testing tools to create best in class quality control program

• Assist in the configuration of Navigant’s Credit Reporting quality control tool to work within the servicing system’s functionality

• Train key personnel to ensure that those conducting the quality control program on an ongoing basis have a thorough understanding of the process

• Document policies and procedures along with job aids, desktop procedures, checklists, and sign offs

• Develop executive dashboards for reporting

• Perform business unit walkthroughs to determine applicable processes impacting furnishing

• Create or review business requirements to ensure compliance with Metro 2 rules and guidelines

• Assess solution design documentation for purpose of ensuring appropriate configuration

• Perform source to target mapping to ensure correct information is being used to create Metro 2 values. e.g. current balance should include interest and fees, amount past due should only be amounts 30 days or more past due etc.

SECTION IIIREPRESENTATIVE ENGAGEMENTS


Company Engagement Summary Description

Large National Bank FCRA Current State Assessment and Remediation

Navigant was engaged by a large national bank to conduct current state assessments, data analytics, and tradeline testing for their Mortgage, Home Equity and Credit Card, Auto and Deposit lines of business. At the direction of outside counsel, Navigant performed the following: Current State assessment of the Bank’s compliance with FCRA requirements via

P&P review, Metro 2 data analytics and tradeline testing; Developed future state Credit Reporting operating model and an organizational

structure for a centralized Credit Reporting group; Drafted of policies and procedures to ensure adherence to FCRA 1022 CFR

Appendix E Lead remediation efforts of all process, procedure and data issues identified including engaging with the Bank’s external sub-servicers and furnishing vendors; and

Conducted executive level training on FCRA requirements.

Top Five Non Bank Mortgage Servicer

Credit ReportingReview

Navigant assisted a top five non bank mortgage servicer to assess the accuracy and integrity of it’s Metro 2 file. To do this Navigant performed data analytics on the Metro 2 file and reviewed key fields at a tradeline level. The assessment identified accounts without dates of first delinquency where required, incorrect Payment History Profiles, Current Balance calculation errors and missing Actual Payment Amounts.

Top US Retail BankFCRA and Metro 2 Credit Reporting Programmatic Assessment

As part of the Bank’s efforts to further improve its policies, procedures, and processes associated with FCRA and Metro 2 related credit furnishing activities, Navigant was engaged to provide an independent programmatic assessment. In this review Navigant performed the following: 1) Evaluated potential gaps identified by the Bank; 2) Assessed the approach conducted to identify the potential gaps and determine if there were any other areas which required additional assessment; 3) Categorized each of the identified gaps; 4) Provided a priority for the remediation of such gaps; and 5) Provided recommendations on remediation approach and strategy.

National Provider of Student Financial Aid Services

Metro 2 Credit Reporting Process Review and Analysis

Navigant was engaged to perform a detailed review of furnishing operations and related system processes which ultimately result in the creation and submission of Metro 2 files to the CRAs. This review entailed end-to-end process walkthrough of Metro 2 submissions, data analytics and a review of a sample of accounts to determine root cause and provide remediation recommendations for inaccuracies found. Review also included management of go forward system enhancements and remediation plans.

REPRESENTATIVE ENGAGEMENTSFCRA / METRO 2



National Used Car Dealer and Automobile Finance Company

Independent Consultant

As the Independent Consultant engaged as part of a Consent Order, Navigant provided an assessment of compliance management systems, internal control systems, and compliance audit procedures related to FCRA. The engagement analyzed compliance with appropriate collection and furnishing practices, as well as developed recommendations on appropriate staffing models, facilities, and the systems necessary to furnish accurate information to the CRAs.

Automobile Finance Company Independent Consultant

Navigant was engaged as an Independent Consultant under a Consent Order to review and develop an audit report to assess compliance with information furnished to the CRAs. The scope of the engagement included the assessment of the process of identification of “all inaccurate” accounts and credit information furnished to the CRAs as a result of Systemic Inaccuracies and a validation of the Metro 2 reporting / customer account information system.

Top Five Captive Auto Finance Company

Credit Reporting, Policy & Procedure and Business Requirements Review

Navigant assisted a top five auto lender reviewing Policies & Procedures and their furnishing file to detect inconsistencies with FCRA or Metro 2 reporting standards. Navigant provided recommendations related to improving controls including creating monitoring dashboards for executive reporting to track disputes and rejected records from the CRAs. Navigant created detailed remediation plans for any identified inconsistencies. Additionally we also reviewed business requirements documentation for new system implementation for any inconsistencies with the Metro 2 guide.

Top Ten Auto Finance Company

Credit Reporting Business Requirements and System Testing

Navigant is working with a top 10 auto finance company to assist in developing business requirements related to furnishing requirements for both leased and financed automobiles. Project involves developing detailed specifications to support IT program changes being developed to support compliance with Metro 2 guidelines. Upon completion of program changes Navigant will also be assisting with user acceptance testing.

Installment Loan Provider Bankruptcy Credit Reporting Current State Assessment

Navigant was tasked with performing a deep dive analysis on the company’s ability to meet specific bankruptcy related Metro 2 requirements. Navigant reviewed how accounts in bankruptcy were reported over time based on different reporting requirements by chapter (Chapter 7, 11, 12 and 13), number of consumer on an account (filer and non-filer) and by bankruptcy status (filed, plan confirmed, dismissed, withdrawn, discharged) to identify potential issues. Navigant’s report identified issues specific to bankruptcy reporting requirements, and also identified ancillary areas that were reported inaccurately but fell outside bankruptcy specific scenarios or requirements.





Installment Loan Provider Credit Reporting / FCRA Assessment

Navigant was engaged to perform a current state assessment of the client's Metro 2 file generation and reporting process. Navigant initially performed an assessment of the client's policies and procedures to help ensure that proper documentation was in place for the credit reporting process. After gaining an understanding of current state processes, Navigant performed account observation and testing on a judgmental sample of accounts for a given month's Metro 2 file to identify systemic issues with calculation logic. Navigant also reviewed a selection of soft pull credit reports and compared the information displayed against the Metro 2 file provided to determine whether credit reporting agencies may be processing data communicated inaccurately.

Subprime Auto Lender Independent Consultant

Navigant was engaged after the client entered into a consent order requiring them to secure and retain an independent consultant with specialized experience in consumer information furnishing. Navigant was responsible for conducting an independent review of client's consumer-information furnishing policies, procedures, practices and systems. The focus of this project involved sample testing / data analytics to confirm compliance with Metro 2 guidelines. Navigant evaluated clients written polices and procedures for compliance with § 1022.41, § 1022.42, and 12 CFR 1022 Appendix E. as well as it's furnishing practices and controls to ensure the accuracy and integrity of the consumer account information furnished to CRA's. Finally, Navigant prepared a report documenting its findings and recommendations and submitted it to the clients board of directors.

Large National Bank FCRA Current State Assessment

A top national bank was concerned with their ability to furnish accurate data on consumers to credit reporting agencies given the increased risk of regulatory oversight for data furnishers. Navigant was engaged to help assess the current state of credit reporting processes and the bank's compliance with reporting requirements, identify issues and assist with remediation activities where necessary. Navigant carried out three phases of analysis to evaluate the bank's current state credit reporting processes. First, Navigant reviewed the organization's P&Ps to identify improvement opportunities. Next, Navigant ran a series of proprietary scripts against a sample Metro 2 credit reporting file provided by the bank to identify systemic issues through a serious of business and Metro 2 reporting rules. Navigant also provided the organization with a detailed assessment of potential fields and areas where credit reporting accuracy needed to be improved.

SECTION IVSELECT MANAGEMENT BIOS


Mr. DelPonti is a Managing Director in the Consumer Finance practice and based in the Charlotte, NC office. He co-leads the Mortgage Banking – Financial and Operational Risk Management Practice providing consulting services in all aspects of consumer and mortgage banking related activities including risk assessments, strategy, and reengineering related reviews.

Mr. DelPonti has extensive experience with over 25 years in mortgage, consumer and finance banking, distressed workouts, capital markets operations, loan valuation and restructuring, portfolio asset management, financial due diligence, post merger integration, lending best practices, mortgage servicing reviews, and risk management including bank (OCC/OTS/FDIC/CFPB) regulatory and compliance management. He is currently leading bank work on FCRA related reviews both from a regulatory (CFPB focus) and Metro 2 guideline perspective. He is a former partner at PricewaterhouseCoopers, LLP where he managed business advisory and audit services focused on top 10 consumer mortgage banks.

Prior to re-joining Navigant in August of 2010, Mr. DelPonti was founder and CEO of a distressed mortgage special servicing and asset management company, where he grew annual revenues from zero to over $25 million in less than 3 years. He also was Chief Risk Officer for a $30 billion thrift bank.

JOHN DELPONTIMANAGING [email protected]: 704.347.7650 | Mobile: 704.877.0441

SELECT MANAGEMENT BIOSJOHN DELPONTI


Beji Varghese is a Managing Director within the Consumer Finance practice group of Navigant. Mr. Varghese specializes in the area of governance, risk and compliance and has advised multiple companies in the design and implementation of effective financial reporting internal controls.

Mr. Varghese has worked on multiple large bank and non-bank FCRA related projects from a regulatory (CFPB focus) perspective. In addition, he has been intimately involved in helping mortgage servicers mitigate the current issues affecting their foreclosure, bankruptcy and mortgage servicing processes. He recently moderated a panel of industry experts at a regulatory conference discussing the impact of the current consent orders, the potential impact of the CFPB and other related issues. He is the author of “Fixing a Flawed Process” discussing the complexities of implementing a Single Point of Contact within the current mortgage servicing environment in the November 2011 issue of the Mortgage Banking magazine – a premier mortgage banking publication.

Mr. Varghese has led credit reporting reviews, risk and compliance reviews, distressed workouts, consent order reviews and lending best practice reviews for the top 20 US consumer finance companies.

Mr. Varghese also has a strong technology background having lead multiple data migration and warehousing projects for the top ten mortgage banks.

Prior to joining Navigant, Mr. Varghese was the COO at a specialty servicer. In that role, he was responsible for growing the business ($600 million in UPB to $ 3.5 billion in UPB) and for operations management and servicing system performance improvements.

BEJI VARGHESEMANAGING [email protected]: 704.347.7639 | Mobile: 980.333.7763

SELECT MANAGEMENT BIOSBEJI VARGHESE


Mr. King is a Director in the Consumer Finance practice based out of the Houston office. He has extensive project management and consulting experience across a wide variety of financial service functions. Mr. King has lead engagements covering risk management, compliance, data extraction and analysis, systems integration, systems development and document management. He is a Certified Fraud Examiner and has been a team leader and project manager for compliance reviews, vendor audits and government inquiries for numerous companies across the world.

Mr. King has conducted numerous current state assessments relating to FCRA. The assessments include reviews of policies and procedures pertaining to disputes, furnishing and usage, an evaluation of Metro 2 files submitted by clients to the CRAs, and the testing of tradelines. He has also supervised the teams acting as the Independent Consultant in Consent Orders issued by the CFPB related to FCRA. He has assisted a wide variety of clients in the auto, student and mortgage lending industries, some of whom are furnishing millions of tradelines a month and investigating thousands of disputes.

Mr. King has been heavily involved in the development of various Navigant tools, including our online loan review tool and suite of credit reporting modules. This has involved managing business analysts and software developers, overseeing version releases, leading user acceptance testing, drafting business requirements documentation, designing reporting, and soliciting feedback from end users for enhancements.

DAVID [email protected]: 713.646.5038 | Mobile: 713.294.6025

SELECT MANAGEMENT BIOSDAVID KING

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FAIR CREDIT REPORTING ACT / METRO 2 CREDIT ... - …/media/www/site/downloads/financial... · services and tools. fair credit reporting act / metro 2 ® credit reporting