Services

Consent Order & Regulatory Remediation

Turn regulatory commitments into controlled, demonstrable change.

Henna83 helps banks, mortgage lenders, servicers and subservicers translate remediation mandates into coordinated delivery across data, processes, people and systems. We connect executive governance with the operational changes, technology requirements and evidence needed to address deficiencies and sustain stronger controls.

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The questions we hear

Can we trace each order provision to an accountable owner, committed date, delivery output and evidence?
Why do reported completion rates differ from what compliance and validation teams can substantiate?
Which data, workflow and vendor dependencies could prevent us from meeting a commitment?
How do we correct servicing or lending processes while maintaining daily operations?
Can we identify affected accounts, explain exceptions and reconcile remediation results?
What must change in the operating model so the same findings do not recur?

The challenges underneath

Disconnected commitments

Obligations are tracked in spreadsheets and presentations, while requirements, defects, tests and approvals sit in separate systems. A green status does not establish that a requirement has been fulfilled.

Fragmented data and evidence

Loan records, payment histories, dispute logs, complaint data, borrower correspondence, vendor files and test evidence use different identifiers, event dates and definitions. The program cannot reliably connect an issue to the affected population or implemented correction.

Controls outside the platform

Teams rely on manual workarounds because approved business requirements have not become configured workflows, supported exception handling or retained decision history. Source-to-target mapping, vendor interfaces and system release dependencies become part of the remediation critical path.

Closure without sustainability

Revised procedures exist, but training, ownership, recurring testing and escalation remain unresolved. Delivery teams need clear evidence requirements and independent challenge before presenting a completion claim.

Capabilities

Mandate-to-delivery architecture

Translate order provisions and compliance-approved interpretations into a traceable obligation register: accountable owner, required output, dependency, deadline and completion evidence. Distinguish consent orders, examination findings and internal issues; preserve each item’s source and authority.

Remediation office and executive governance

Mobilize workstreams across operations, technology, data, compliance, risk, legal, audit and vendors. Establish decision rights, escalation thresholds, capacity planning, dependencies and a reporting cadence that makes delays and evidence gaps visible.

Data and reporting remediation

Reconcile issue populations, loan/account identifiers, event histories and reporting feeds. Establish lineage, quality checks, ownership and controlled management reporting so leaders can explain both progress and remaining exposure.

Process, platform and vendor controls

Convert approved requirements into business/functional specifications, workflow changes, exception rules and test scenarios. Coordinate changes across core banking, LOS, servicing, case-management and vendor platforms, including regression and operational readiness.

Consumer-impact workstream coordination

Where required, structure identification, investigation, approved remediation execution and reconciliation of affected populations. Legal/compliance and appropriate specialists approve restitution methodologies, communications and substantive decisions.

Evidence and validation readiness

Define acceptance evidence from the start. Build a versioned evidence index connecting commitments to implemented changes, test results, approved procedures and responsible reviewers. Coordinate independent challenge and validation with appropriate risk, audit or qualified third parties; preserve independence from delivery.

Sustainability and handover

Embed accountable process owners, training, recurring control checks, issue escalation and measures of effectiveness. Move beyond project completion to evidence that the changed operation continues to work.

Outcomes we work toward

Traceable obligations, corrective actions and acceptance evidence.
Accountable workstreams with realistic sequencing and visible dependencies.
Consistent executive reporting of delivery progress and evidence readiness.
Implemented and tested changes to data, workflows and platform controls.
Organized documentation to support appropriately independent validation.
Established ownership, monitoring and escalation after program handover.

Approach & outputs

Step 1

Frame the mandate

Confirm scope and approved interpretations with client legal/compliance; inventory commitments, current work and evidence. Output: obligation register and delivery perimeter.

Step 2

Diagnose the dependencies

Connect issues to source data, workflows, controls, vendors and accountable owners. Output: gap/dependency assessment and prioritized corrective-action roadmap.

Step 3

Mobilize and execute

Govern delivery, translate requirements, coordinate changes and tests, and maintain decisions and evidence. Output: integrated plan, workstream reporting and implemented changes within agreed scope.

Step 4

Prepare validation and sustain

Assemble evidence, support independent challenge and establish recurring controls and handover. Output: validation-ready evidence index, sustainability measures and operational ownership.

Platform context

Experience working across client platforms and vendor environments.

Microsoft Power Platform / Power BISharePoint / approved repositoriesServiceNow / Jira / Azure DevOpsFiserv / FISICE Encompass / MSPSagent platforms

Applied in our programs

Who we serve

Banks Mortgage Lenders Servicers Subservicers

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Our perspective

A remediation plan becomes credible when every commitment can be connected to an owner, an implemented change and evidence that the change works. That connection often breaks between the program office, the data estate, the servicing platform and the teams operating the process. Henna83 works across those boundaries, bringing one delivery structure to the mandate and the dependencies beneath it.

Regulatory landscape

Relevant oversight may include the OCC, Federal Reserve, FDIC, CFPB and applicable state banking/mortgage regulators, including NYDFS where relevant. Applicable authority depends on charter, institution, activity, geography and the particular action. FinCEN/OFAC may matter for specialist financial-crime scopes. The FFIEC provides interagency examination guidance; it is not interchangeable with an order-issuing agency. Investor and housing-agency requirements are a separate layer of obligations.

RESPA / Regulation X

Servicing error resolution, information requests, escrow, servicing transfers and loss-mitigation workflows.

Map approved requirements into intake categories, event dates, routing, notices, exception handling and traceable records.

Official reference →

TILA / Regulation Z

Lending disclosures and applicable servicing requirements, including payment processing and periodic statements.

Connect source transactions, calculation logic, disclosure/statement outputs, version control and testing.

Official reference →

FCRA / Regulation V

Credit furnishing accuracy, integrity and dispute handling.

Map furnishing data, account status transitions, dispute routing, investigation records and correction evidence.

Official reference →

ECOA / Regulation B

Equal credit opportunity and applicable notification and valuation requirements.

Translate compliance-approved requirements into decision workflows, notices, data capture and testing; specialist review for fair-lending analysis.

Official reference →

UDAP / UDAAP

Consumer treatment, representations, fees and avoidable harm.

Connect complaints and exceptions to root causes, corrected processes, approved communications and outcome monitoring.

Official reference →

HMDA / Regulation C

Mortgage lending data collection, reporting and disclosure where applicable.

Source-to-report mapping, data ownership, edit checks, reconciliation and controlled submission preparation.

Official reference →

FDCPA / Regulation F

Debt-collection requirements where the entity/activity falls within coverage.

Communication, validation, dispute and furnishing workflow controls; determine applicability with client compliance/legal before design.

Official reference →

SCRA

Applicable protections for servicemembers.

Military-status handling, approved benefit workflows, escalation controls and retained decision evidence.

Official reference →

GLBA / Regulation P; applicable information-security requirements

Consumer financial privacy; information safeguards under the relevant regulator’s requirements.

Data-sharing permissions, privacy-notice workflows, controlled access and evidence retention. Regulation P is the privacy rule, not a substitute for security requirements.

Official reference →

BSA / AML and sanctions — specialist-supported scope

Financial-crime remediation where relevant to the order and institution.

Program governance, data/workflow dependencies and reporting with qualified AML/sanctions specialists; no blanket claim of substantive financial-crime expertise.

Official reference →

Process framework

From commitment to evidence

Illustrative process framework: a servicing error-handling finding is connected to approved requirements, case timestamps, routing rules, vendor changes, test results, procedures and an accountable control owner. The reporting view shows both delivery progress and evidence readiness. Substantive rule interpretation and acceptance criteria are agreed with client compliance/legal; validation is performed by an appropriate independent function.

Henna83 coordinates remediation delivery against client-approved requirements. Legal interpretation, independent validation and order-termination decisions remain with the appropriate advisers, control functions and authorities.

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