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Untitled Document
COMPLIANCE
COMPLIANCE
Performance: Financial & Capital Improvement Programs
Contract Compliance Monitoring
Gap Analyses & Documentation
Remediation Management
Audits are fundamental to public accountability for federal programs and take either of two forms - Financial or Program Compliance. Our firm has developed a practice based on serving agency needs for the latter - Program Compliance. Leveraging a 26-year history as a fiduciary, our audit personnel combine discipline in assessing technical compliance with program performance and reporting mandates, with practical knowledge of industry best practices for the management of such programs.

Historically, our experience stems from conducting multi-year programs for the workout and restructure of loan and real property portfolios for government agencies and regulators. Our Program Compliance experience has continued to evolve as the result of our nationwide involvement in assisting regulators resolve the most recent bank failure crisis.

Whether associated with failed banks and their portfolios of non-performing commercial and residential loans, or the reconciliation/realignment of housing subsidies to market conditions, our firm supports compliance oversight with internal and field recognizance, monitoring and analysis.
Representative Engagements
Clients

Federal Deposit Insurance Corporation, Department of Resolutions and Receiverships (FDIC) - 2009 to Present
Scope
The FDIC utilizes the "Shared Loss Program" as its preferred method of resolving bank failures nationwide, including Commonwealth territories. Within this program, assuming financial institutions (AIs) acquire the loan portfolios of failed banks, subject to a complex contract known as the Shared Loss Agreement (SLA). Signet was selected by FDIC to provide oversight and surveillance of 29 failed institution portfolios, nationwide (September 2014). Signet mobilizes and deploys as many as four compliance audit teams to simultaneously conduct on-site AI visitations. The objective of these visitations is to test and document adherence to SLA terms in the resolution of troubled loans (residential and commercial), claims against SLA loss guarantees and comprehensive accountability. On behalf of the FDIC, Signet is currently monitoring SLA compliance involving more than 137,000 loan asstes with a book value of nearly $15.5 billion. Noteworthy services include:

Develop unique audit programs for each AI visitation, enabling comprehensive coverage of all required compliance parameters.
Perform audit testing as the basis for providing exception or gap reporting, together with recommendations for remediation.
Apply industry best practice reviews, regarding the disposition management and recovery performance of AI asset portfolios.
Analyze each AI's portfolio decision making and documentation processes for loan workouts and foreclosed asset dispositions to evaluate the appropriateness of monetary impacts to the FDIC.
Assess each AI's fiscal, confidentiality and data management controls and compliance with all agreed upon procedures.
Assist in alignment of AI and FDIC interests as findings and remediation action plans are documented, discussed, implemented and subsequently monitored through final resolution.
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