Advisory

Our governance, risk management, and compliance advisors have decades of experience applying tried-and-true methodologies to address compliance and risk management needs. We help clients respond to regulatory recommendations, matters requiring attention, informal and formal actions.  These services include:

Governance

• Evaluating board composition, committee charters, and structures
• Designing communications processes to measure results and maintain strategic alignment
• Assessing organizational risk culture, business ethics, and market conduct and integrity programs
• Developing whistleblower reporting systems, trend analysis, and fraud prevention and detection programs
• Enhancing investigations procedures and escalation protocols
• Improving oversight efficacy through customized dashboards, metrics, and information packages
• Providing strategic and tactical advice on matters requiring board attention and remediation
• Evaluating and developing governance structures, including policies and procedures
• Assessing and developing training, education and awareness programs for boards, management, and employees through interactive, engaging, and informative learning tools and methods

Risk

• Assessing and recalibrating Three Lines of Defense risk mitigation and controls
• Conducting risk assessments to identify inherent risk factors and risk mitigation strategies
• Developing and implementing enterprise risk management programs
• Formulating operational risk frameworks, including business resilience and continuity planning
• Designing and developing third-party and vendor risk management programs

Compliance

• Conducting program operations, monitoring, and planning based on U.S. Federal Sentencing Guidelines for Organizations and related international compliance program frameworks
• Assessing Codes of Conduct and Business Ethics for employees, boards and third-parties
• Designing regulatory and consumer compliance remediation programs
• Creating financial crime compliance (sanctions, money laundering, bribery & corruption)
• Overseeing BSA/AML model validations, system calibrations and implementations
• Enhancing Know Your Customer/Enhanced Due Diligence and Customer Identification risk processes
• Enhancing OFAC and sanctions screening programs
• Overseeing lookback remediation and remediation project management

We provide analysis and support in several critical areas for financial institutions, including crisis management, credit risk assessments, liquidity strategies, operational risks, bank stress-testing, prudential regulatory standards, and complex regulatory applications. Our services include:

• Reviewing and evaluating policies, balancing sheet management, and funding strategies
• Evaluating contingency funding strategies, escalation, and communication structures and protocols
• Accessing controls and staffing, governance programs, contingency plans
• Evaluating credit risk identification, monitoring, and reporting
• Conducting allowance for loan and lease loss assessments and reviews
• Performing model validations and stress-testing scenarios
• Performing transaction and look-back reviews and forensic investigations
• Advising on regulatory enforcement actions and remediation strategies
• Providing remediation and implementation plans to address regulatory and/or audit shortcomings or criticisms

Our experts have unmatched industry expertise covering a vast array of banking products, services, and regulatory practices. Our regulatory and compliance expert witnesses have provided written reports and testimony in some of the largest bank regulatory matters over the last decade.

​With decades of first-hand industry insights as former regulators and senior executives at leading financial institutions, bank leaders and their attorneys look to our expert witnesses for credible and practical analysis to help resolve complex business and litigation challenges facing financial institutions and their boards. Our expert witness services also include challenges to various enforcement actions and appeals from material supervisory determinations, before such disputes reach formal litigation proceedings.

​Many of these matters comprise alleged negligence, misrepresentation, and fraud asserted against officers and directors of premiere global financial institutions and top tier banks, in matters such as:

• Lending Practices and Loan Underwriting: Evaluating mortgage, commercial, and consumer lending standards
• Bank Fraud and Misconduct: Investigating fraud, waste, embezzlement, money laundering, and insider misconduct
• Regulatory Compliance: Reviewing adherence to FDIC, OCC and Federal Reserve regulations, guidance, and supervisory requirements
• Commercial Banking Disputes: Assessing contracts, loan servicing, and bank-customer relationships
• Risk Management and Internal Controls: Examining policies to prevent fraud, mismanagement, or losses
• Mergers and Acquisitions: Evaluating due diligence, disclosures, and financial transactions

Our former bankers and senior regulators help management teams build effective business strategies. We offer unparalleled insights in devising such plans. Our team also has extensive experience with de novo bank applications. Our services include:

• Evaluating and developing business plans and financial modeling
• Designing go-to-market banking and branch franchise strategies
• Assisting product design and market penetration strategies
• Providing application expertise for de novo bank and industrial loan company formation
• Assisting and supporting regulator and investor presentations
• Assisting in developing digital banking strategies
• Designing climate change and sustainability programs

Our former bankers and senior regulators help management teams build effective business strategies. We offer unparalleled insights in devising such plans. Our team also has extensive experience with de novo bank applications.

• Evaluating and developing business plans and financial modeling
• Designing go-to-market banking and branch franchise strategies
• Assisting product design and market penetration strategies
• Providing application expertise for de novo bank and industrial loan company formation
• Assisting and supporting regulator and investor presentations
• Assisting in developing digital banking strategies
• Designing climate change and sustainability programs

Institutions need to remediate and manage risks arising from cybersecurity, data privacy and enterprise content management. Data security requirements are more complex than ever, and we have innovative and rational solutions to help mitigate these high-risk areas. We provide the following services:

• Assessing cybersecurity and data privacy
• Assessing information security and reporting obligations, including attestations
• Strengthening privacy and information protection protocols
• Reviewing records retention and information management systems and policy implementation
• Assessing and testing business resilience and continuity
• Analyzing business processes and workflow management

We assist our clients with activities including:

• Reviewing and evaluating compliance management systems, programs, policies, and procedures
• Evaluating Community Reinvestment Plans and monitory processes
• Evaluating consumer compliance risks, monitoring, and reporting
• Building Community Reinvestment Act programs, including Strategic Plans for CRA
• Performing Fair Lending assessments and evaluations

Our team has rich experience with court- and government-appointed independent oversight and remediation services for troubled institutions. Central banks and agencies turn to us in these situations for integrity, subject matter expertise, reliable investigative results, and objectivity. Our team of former bank supervisors offers large bank resolution planning expertise from hands-on experience. Our services include:

• Supporting regulatory reform implementations for large commercial banks
• Overseeing and supervising business wind-downs, liquidations, and asset dispositions
• Providing independent monitoring for deferred prosecutions, liquidations, and receiverships
• Supporting deposit insurance and bank resolution programs for international and domestic regulatory agencies
• Assisting with resolution planning and interpreting regulatory guidance and plan submissions
• Evaluating the reasonableness of resolutions plans, including assumptions, strategies, and capabilities
• Interpreting regulatory expectations and helping address concerns for successful plan submissions