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  • Stephen M. Cross

    Stephen Cross

    Senior Director

    Mr. Cross has 30 years of experience in federal financial institution regulation, including with the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Federal Housing Finance Board (FHFB), and the Federal Housing Finance Agency (FHFA). He served as Director for Industry and Financial Analysis and Deputy Comptroller for Compliance Management (Policy) at the OCC; Director of Compliance and Consumer Affairs at the FDIC; Director of Bank Supervision at the FHFB; and Deputy Director and (Acting) Chief Operating Officer at FHFA. In addition to overseeing the consumer compliance supervisory programs at both the OCC and FDIC, Mr. Cross served as a member and chairman of the Federal Financial Institutions Examination Council (FFIEC) consumer compliance task force. As a member of the FHFA's Senior Executive Committee, Mr. Cross participated in the development of FHFA policy positions, including positions with respect to loss mitigation, secondary mortgage market reforms, and the oversight of Fannie Mae and Freddie Mac in conservatorship.

    At Wolters Kluwer Financial Services, Mr. Cross specializes in providing pre- and post-examination assistance and strategic advice to financial institution clients. His primary areas of concentration are CRA, fair lending, consumer compliance, governance, anti-money laundering, strategic planning, and risk management. He is a widely-recognized authority on the CRA and Fair Lending. Mr. Cross was one of the principal staff architects of the inter-agency revisions to the CRA regulations, which were promulgated in 1995.

    Immediately prior to joining Wolters Kluwer Financial Services, Mr. Cross was a Managing Director, Alvarez and Marsal Financial Industry Advisory Services. At A&M, Mr. Cross worked with financial institution clients to develop compliance risk assessments, prepare for examinations, and remediate examination matters requiring attention. He also advised clients on matters related to potential reform of the secondary mortgage market and compliance with the Dodd-Frank Act, including resolution planning and Federal Reserve Board supervision of Foreign Banking Organizations in the United States.

    Mr. Cross earned a PhD in economics with a concentration in money, banking, and finance from the University of Virginia. He was an assistant professor of economics at Holy Cross College from 1979-1984, before beginning his career in bank regulation with the OCC in 1984.

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    Unlocking the Code for a Successful CRA Examination
    (Published March/April 2016) In this ABA Bank Compliance article, Stephen Cross unlocks the code for a successful CRA examination, which includes knowing the end game, showing the relevant accomplishments of the bank, and placing a clear emphasis on performance, documentation and metrics.
    Know the End Game: Strategies for Creating a Forward-Looking CRA Plan
    (Published November 2015) Stephen Cross a Senior Director with Wolters Kluwer identifies a trend where federal banking regulators are increasingly requiring banks to prepare a CRA Plan as a condition of an approval.
    Preparing for Exams
    (Published April 2015) In this Mortgage Banking major feature, Wolters Kluwer Financial Services’ Tim Burniston and Steve Cross provide insights, as former banking regulators, on how financial institutions can successfully prepare for an exam.
    New BISG Proxy Methodology – What is it and why should you care?
    (Published January 8, 2015) The new BISG proxy methodology combines geography- and surname-based information into a single proxy probability for race and ethnicity. Learn why you should care and what tools there are to help you collect this data. What you don’t know could hurt you.
    Strengthening Risk Compliance Along Three Lines of Defense
    (Published January 2015) The changing regulatory landscape has introduced increased focus and heightened expectations for financial institutions around risk management and compliance risk management. Building a strong compliance culture and program starts with strategic planning built with the input from frontline units (the first line of defense), compliance units (the second line) and audit (the third line). This article, co-authored by Stephen Cross and Thomas Grundy, provides an overview of the three lines of defense and the role each plays in supporting compliance risk management.  It was published in the January 2015 issue of ABA Bank Compliance magazine.
    Private Student Lending: Time to Meet a Higher Standard
    (Published April 2014) Private student loans are receiving attention from federal and state regulators and enforcement agencies. In February 2014, for example, the CFPB filed a lawsuit against a for-profit college and private student lender accusing the entity of pushing students into higher-cost private student loans that were likely to end in default. This paper is therefore intended to provide guidance to private student lenders to help them meet consumer needs and avoid potentially unfair, deceptive or abusive practices.
    Déjà Vu All Over Again
    (Published March 2014) The Community Reinvestment Act (CRA) was enacted as part of the Housing and Community Development Act of 1977 to combat the “redlining” of neighborhoods where banks were believed to be reluctant or unwilling to lend. Eighteen years later, the initial regulatory framework had outlived its usefulness and was replaced by a new regulatory regime that ostensibly emphasized performance in lending, investment, and services. What are CRA's standards for reviewing performance today?
    Consumer Complaint Management: Understanding Regulatory Expectations
    (Published February 2014) The role of the Consumer Financial Protection Bureau (CFPB) is to receive, record, and process complaints pertaining to financial services offered by banks, thrifts, and other providers of financial services. In this article we will look at complaint handling from the examiner’s point of view and help you identify effective processes that meet or exceed the expectations of the CFPB and the federal banking regulators. The specific elements of an effective complaint management system will vary across institutions, but the key areas to be addressed include complaint intake, escalation, analysis, response, and final resolution.