Crowe Activity Review System Quality at the Source Audit Tax Advisory Risk Performance
With ever-increasing expectations of review processes from various stakeholders, organizations are under pressure to manage one-off reviews and look-backs, as well as business-as-usual processes, with greater efficiency, transparency, and quality. The CARS solution is an adaptive and dynamic tool providing process assurance, workflow management, and quality control. The CARS solution enables institutions to effectively meet these various stakeholder and regulatory expectations.
Crowe Activity Review System The Challenge of Reviews and Investigations Today s financial services businesses must review an increasing number of activities and comply with rising examiner expectations that emphasize consistency and quality of the investigative process. As such, management requires tools that drive efficiency of the review process, embed quality at the source, and provide timely, detailed analysis to meet both regulator expectations and management s own quality and risk management responsibilities. Although case management systems are typically effective at presenting cases to be worked, they do little to ensure consistency and quality of the review process. As a result, institutions incur significant quality control costs to validate that review and investigative activities have been performed accurately and according to established policies and procedures. Examples of when this is problematic include anti-money laundering (AML) suspicious activity reviews, fraud investigations, loan approvals and credit reviews, mortgage servicing reviews, mortgage insurance rescission and repurchase demands, ATM and credit card disputes, and other mandated look-backs and reviews. Meanwhile, other industry and economic trends are creating more challenges: A bank s investigative, review, and follow-up processes must be consistent, yet because financial crimes are growing increasingly complex, the systems used must be flexible and readily adaptable to respond to the newest threats. Examiners and auditors are focusing greater attention on institutions investigative and file review processes, looking for documented, verifiable decision-making steps, along with narrative completeness and consistency. The penalties for failing to meet regulatory expectations are growing, further raising the stakes by increasing the potential costs associated with inadequate processes. Banks and other institutions continue to face narrow margins and ongoing pressure to lower operating costs often leading to reduced staffing even as workloads increase. www.crowehorwath.com 3
Crowe Horwath LLP The Solution The CARS solution is advanced software used by financial institutions across multiple areas to improve efficiency and maintain compliance with regulatory guidance. Developed by Crowe Horwath LLP, the CARS solution is designed to complement and strengthen institutions monitoring, case management, and documentation systems, streamlining the work processes and reducing compliance costs while helping banks meet increasing regulatory expectations for consistency and quality. The CARS solution uses dynamic, configurable questionnaires to guide the user through the review process and confirm that established procedures are followed, appropriate documentation is provided, and quality control is conducted. Descriptive narratives are generated based on the review activity and the steps performed by the user to document each step of the review. CARS technology enables an institution to establish and model its review methods and efficiently reconfigure those processes using adaptive case management technology without the need for costly customization, system redesign, or vendor assistance. The CARS tool collects detailed information at each step of the review process for improved system calibration, along with key risk indicator and key performance indicator reporting and analytics. Moreover, the solution s embedded quality assurance module provides an integrated, configurable quality control function to facilitate independent review of work performed either in line or on an ad hoc basis. The CARS Web-based solution can be hosted and operated by Crowe or brought in-house. Building a Common Platform for Reviews and Investigations An important trend in financial institution management is the convergence of investigative functions and the consolidation of responsibility into a centralized compliance organization. One key to maximizing the potential benefits of such a strategy is the use of a single technology platform, which risk management resources can employ for collecting, documenting, and managing the information required for all their various activity review and investigative processes. CARS technology provides this common platform, which helps institutions by: Creating efficiencies in collecting and documenting components of reviews Providing consistency across geographies and files regardless of the individual performing the review Facilitating consistent, reliable communication with all parties regulators, legal counsel, client management and operations, and external review staff Capturing facts and evidence for documentation and distribution Enhancing decision-making capabilities 4
Crowe Activity Review System Adaptable and Readily Configured As work processes change or requirements are added, the CARS solution provides the ability to quickly update processes through user configuration rather than requiring custom programming. In this way, the CARS solution gives controlled flexibility without the need for continuing vendor support or assistance. Because it is so readily adaptable, the CARS tool is widely used to manage and execute a variety of review and investigative work processes, including: AML. Both business-as-usual transaction monitoring and look-backs, including transaction alert reviews, suspicious activity report generation, quality reviews, customer due diligence, and enhanced due diligence. Mortgage representation and warranties. Responses and followups to rescission and repurchase demands involving Fannie Mae and Freddie Mac loans. Fraud reviews. Review of suspicious activity tied to potential internal and external fraud. Credit and loan reviews. Assessments and reviews of commercial loan risk ratings, credit analyses, documentation, and loan administration issues. Mortgage file reviews. Reviews of past mortgage servicing activities and compliance with specific state requirements. Branch audits. Reviews and checklists for compliance with standard required operating procedures and regulatory requirements. The CARS solution can be configured readily for use in many other applications in the financial services industry, as well as in other industries and settings, such as recording, managing, and following up on consumer complaints. CARS technology can be applicable in virtually any setting in which adherence to established procedures and work processes must be monitored and reviewed. www.crowehorwath.com 5
Crowe Horwath LLP Primary Activity Sources Other Internal and External Events Primary Data Sources System Administration Module External Systems Integration Handler CARS Solution Work Queue Prioritization and Distribution Workflow Manager System Administration Module Dynamic Work, Steps, and Responses Narrative Generator Quality Control Dashboard and Reporting Module Security and User Auditing Activity Logging 6
Crowe Activity Review System How CARS Technology Works CARS technology leads users through a series of questionnaires, which reflect defined processes or compliance steps to verify that appropriate actions have been taken. The system is dynamic the questions, checklists, and next steps that appear will change depending on users responses. Questions are arranged into logical groupings to help organize complex workflows or compliance processes. In addition to guiding individuals through defined work processes, the CARS solution contains a built-in workflow engine, which queues and prioritizes review items and routes work along a path configured to match the institution s review, investigation, and quality control processes. The CARS System Administrator Module organizes complex processes into stages so individuals with the appropriate skill sets address each stage. Work or file assignments are queued individually or drawn from a common pool of available files. The CARS Workflow Manager determines the most effective distribution of individual assignments, routing high-risk or high-priority assignments to designated processors or analysts. The CARS Dashboard and Reporting Module provides visibility and transparency for management follow-up, as well as full documentation for use by examiners and auditors, all in real time. The integrated management dashboard monitors all aspects of individual and team performance, as well as quality and trends. The CARS Narrative Generator automatically generates a narrative summary based on the workflow steps taken and the documentation recorded at each step. The built-in Quality Control Module manages both regulatory mandated and ad hoc quality review processes. Benefits of the CARS Solution As banks and other financial services providers struggle to manage increasingly complex review, investigative, and examination processes, a growing number of organizations have discovered that CARS technology allows them to achieve a number of important objectives, including: Improved quality. Measurable process compliance and quality control. More effective monitoring. Includes the ability to more quickly identify trends and more efficiently manage staff. Increased responsiveness. Greater flexibility to adapt to evolving requirements and challenges. Greater productivity and efficiency. Enables management to assign work and manage assignments more effectively while lowering barriers to cross-training staff. www.crowehorwath.com 7
Contact Information Contact Crowe for more information on how CARS technology can benefit your organization for process assurance, workflow management, and file review capabilities. Brian J. Kloostra, Principal +1 616 752 4219 brian.kloostra@crowehorwath.com Ronak S. Desai +1 317 208 2556 ronak.desai@crowehorwath.com About Us Crowe Horwath LLP (www.crowehorwath.com) is one of the largest public accounting, consulting, and technology firms in the United States. Under its core purpose of Building Value with Values, Crowe uses its deep industry expertise to provide audit services to public and private entities while also helping clients reach their goals with tax, advisory, risk, and performance services. With offices coast to coast and 3,000 personnel, Crowe is recognized by many organizations as one of the country s best places to work. Crowe serves clients worldwide as an independent member of Crowe Horwath International, one of the largest global accounting networks in the world. The network consists of more than 200 independent accounting and advisory services firms in more than 120 countries around the world. www.crowehorwath.com When printed by Crowe Horwath LLP, this piece is printed on Mohawk Color Copy Premium, which is manufactured entirely with Green-e certified wind-generated electricity. In accordance with applicable professional standards, some firm services may not be available to attest clients. 2016 Crowe Horwath LLP, an independent member of Crowe Horwath International crowehorwath.com/disclosure RISK-16000-029A