Compliance Management System (CMS)

Berkshire’s Compliance Management System (CMS) involves of a thorough review of a firm’s policies and procedures that guide employees’ adherence to laws and regulations. The CMS includes independent testing of an institution’s transactions to determine its level of compliance with consumer protection laws, as well as the effectiveness of, and adherence with, policies and procedures.  As a part of the CMS review Berkshire Group and its affiliate, Cognitive Options Group, will conduct the following:  

    • Policies & Procedures Gap Review
      • Fully outsourced solutions:
        • Access to a shared network drive housing policies and procedures.
      •  Continual monitoring:
        • Notifications regarding regulatory changes directly impacting current policies and procedures
        • Ongoing monthly policy & procedure status reminders of required revision dates to current policies
      • Complete tracking on each module:
        • Tracking of all versions of policies and procedures, from initial to final

 

    • CFPB Pre-Examination Review
      • Complete high-level review and assessment of mortgage origination compliance program:
        • Establish compliance responsibilities
        • Communicate those responsibilities to employees
        • Confirm the that responsibilities for meeting legal requirements and internal policies are incorporated into business processes
        • Confirm responsibilities are carried out and legal requirements are met
        • Confirm corrective action and updates to tools, systems, and materials have taken place.  
      • Comprehensive transactional testing to help identify remediation strategies

 

  • AML/SAR Policies, Procedures and Controls for Non-Bank Lenders
    • AML compliance oversight
    • Suspicious activity monitoring system
    • FinCEN AML and SAR online training