CoNSUMER FAIR LENDING

Cornerstone offers fair lending data analysis for all types of consumer loans including mortgages, automobiles, and unsecured lines of credit. Cornerstone provides a comprehensive analysis to determine potential disparities with respect to pricing, underwriting, steering, redlining, and lending within the institution’s own community.

HOME MORTGAGE DISCLOSURE ACT (HDMA)

Cornerstone offers a thorough HMDA data review, which will verify the data entry from the institution’s loan file to the institution’s HMDA Loan Application Register (LAR) - Every HMDA data point for each loan is reviewed and the errors are analyzed to determine possible issues with the overall data.

COMMUNITY REINVESTMENT ACT (CRA)

• Technical Review – Cornerstone provides a technical review of the institution’s CRA disclosure requirements, including an audit of its CRA public file and branch disclosures.
• Substantive Review – Cornerstone offers a comprehensive review of the institution’s entire CRA program, including its services, investments, and loans made with respect to community development. The review analyzes whether the institution is meeting the needs of the community through the products and services that it provides.

COMPLAINTS ANALYSIS AND REVIEW

This review can analyze both decisions made in response to specific complaints and provide an understanding of an institution’s weaknesses, gaps and potential UDAAP risks.

ADVERTISING REVIEW

• Single Advertisement Review – Cornerstone will review the marketing piece for compliance and content, based on the applicable regulations.
• Website Review – Cornerstone will review each page of the website and analyze whether the content and images are compliant with all applicable guidelines and regulations.
• Advertising Program Review – Cornerstone will analyze the marketing pieces, website and overall advertising strategy to determine whether the program is compliant with all applicable regulations including fair lending. Cornerstone will also analyze whether the marketing distribution effectively reaches the institution’s entire servicing area.

BUSINESS CONTINUITY PLANNING

Testing portions of the institution’s business continuity plan to identify potential weaknesses and omissions.

NEW PRODUCTS REVIEW AND ANALYSIS

This provides an industry perspective on a prospective new product (or enhancements to existing products) and outlines potential areas of confusion or lack of understanding.

Third Party/Vendor Management Program Review

This review analyzes the institution’s effectiveness in maintaining oversight in respect to critical third parties and vendors.

truth in lending (tila)

• Real Estate Settlement Providers Act (RESPA) and combined disclosures – Cornerstone provides reviews in respect to APR and finance charge tolerances, the initial disclosure requirements to changes in circumstance to the final HUD-1 Settlement Statement and also reviews the disclosure timing requirements with respect to this Act.
• Truth-In-Lending (TILA) Billing Dispute and Electronic Funds Transfer Act (EFTA) Error Resolution Cases, including reviews on timing, decision review and required disclosures.