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AI & Technology Why Commonwealth Cost Calculator InsightsThe practice this firm was founded on.
We opened in 2008 as a mortgage compliance and fair lending consultancy. Everything else we do came later. If your examiner is arriving, your LAR is shaky, or your pricing has never been tested, this is the original work.
Policy · Fair lending · Exam readiness · Independent testing
A compliance management system, not a binder.
Policies, testing and audit are the three parts regulators expect to see working together. Most findings come from the seams between them.
Fair lending & pricing
Matched pair analysis on underwriting decisions, adverse action review, and pricing regression tested against key demographics. Run annually, this is what surfaces disparate treatment or disparate impact before a regulator or a plaintiff does.
Policy & internal audit
Policy and procedure development, then internal audits that test whether your procedures actually meet your own policy. We also test the testers: independent QC review checks that your QC department is producing accurate findings and real trend analysis.
Data & filings
HMDA LAR audits before you submit, not after a correction notice. Inaccurate data means refiling at your expense and, in some cases, civil money penalties. MERS annual audits handled alongside.
Exam readiness
Mock FRB, FDIC and CFPB audits that stress test your lending policies before the real thing. Plus AML and BSA validation on the two-year cycle, CRA program review with peer comparison, and warehouse due diligence for line fraud risk.
Compliant and profitable are not opposites.
A control that nobody can operate is not a control. Recommendations have to survive contact with a working origination shop.
Find out where you actually stand
Before recommending anything we establish what your policies say, what your staff do, and where those two have drifted apart. That gap is where findings live.
Test it the way an examiner would
Same analysis, same statistical methods, same questions- run by people who have sat on both sides of an exam. Better to hear it from us first.
Fix what the findings show
Policies rewritten, procedures reworked, staff trained on the specific failure. A report that identifies a problem without closing it has moved the risk onto paper, not off your balance sheet.
Keep it running
Fair lending and pricing analysis annually, AML and BSA every two years, MERS yearly, HMDA every filing. We track the calendar so a required review never becomes a missed one.
Regulators are not bluffing on data quality.
Recent enforcement has turned on HMDA data accuracy specifically: repeated submission errors at one lender, falsified data at another. Data quality is no longer a clerical matter, and an independent review before filing costs considerably less than a correction after one.
Start with a confidential conversation.
Tell us what is coming (an exam, a filing, an acquisition, or a worry you cannot place) and we will tell you what we would look at first.