Control Framework

What we do

Lenders and servicers in today’s Dutch mortgage industry face intense regulatory scrutiny. They must conform to stringent operating and processing standards and demonstrate robust risk oversight to identify and remediate exposure in a timely fashion. In our opinion and experience, reliance on internal or ISAE3402 audits it is not enough to identify current and future critical risks which can result in material consequences.

With our in-depth knowledge of the mortgage market, we developed the Mortgage Control Framework, the first in the industry to focus on identifying and mitigating substantive risks across the entire mortgage supply chain through in-depth control of in and output and rigorous due diligence. It is an essential reinforcement to a lender’s regular first line of defence.

The Mortgage Control Framework is based on three steps that can be easily adapted to the organisation’s needs.

  1. Using a systematic method, we identify risk points in policies, procedures, documents and processes. For every risk point we determine the severity of the risk, how it should be monitored and how often.
  2. Once the Framework is set up, we conduct periodic reviews of a sample of loan files. Unique to this approach, we follow the customer journey through every process step from the point of origination, however many years ago, and every change and action since to ensure that all documents and output still match all terms and conditions.
  3. We recommend effective improvements to policies or processes which we can help to implement or oversee and review.

The Netherlands office

+31(0)88 1820222

United Kingdom office


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