Germaal is a regulatory compliance professional with over thirteen years of experience working with financial services institutions in consumer compliance, investment management, and securities regulation. Germaal specializes in advising institutions on compliance with consumer protection and fair lending laws, rules, and regulations (e.g. Servicemembers Civil Relief Act (SCRA), TILA-RESPA Integrated Disclosure (TRID), RESPA Regulation X, Fair Lending laws, Homeowners Protection Act, Home Mortgage Disclosures Act (HMDA), Community Reinvestment Act (CRA), and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)). Within this practice, Germaal advises on consumer regulatory compliance including compliance management program design, implementation, and assessment; compliance testing; and all aspects of compliance in relation to consumer financial products and services throughout the product lifecycle; from product development, advertising and marketing, model development, to originations, routine and default servicing.
Germaal’s financial services experience includes regulatory compliance consulting for the financial services industry as well as consumer response and protection policy work while at the CFPB. He has advised financial institutions and financial service providers on various regulatory compliance matters, focusing on consumer compliance assessment and enhancement activities. In handling complex matters involving regulatory compliance, Germaal incorporates regulatory expectations and industry best practices.
Germaal’s engagements range from compliance program design and assessment to consumer remediation to detailed file reviews and compliance audits. Examples include:
- Led the creation of an inventory of compliance requirements across a fintech’s businesses and products identifying its regulatory obligations based upon the Institution’s businesses, legal structure, products, and objectives.
- Led an inherent compliance risk analysis, control identification, design effectiveness and gap assessments for a FinTech personal finance institution.
- Led a 21-state Consent Order mandated comprehensive, independent lookback review of over 40,000 mortgage loan files to assess a mortgage servicer’s compliance with federal and state mortgage servicing laws and regulations.
- Performed remediation validation of mortgage servicing-related corrective action plans to assess the sufficiency of plan design in remediating errors and financial harm and preventing harm from recurring. Responsible for validating the remediation populations and identification logic.
- Led an MRA-mandated, flood insurance-focused, 5-year lookback review of force-placed flood insurance transactions for over 3,000 loans to identify bank loss exposures resulting in non-compliance.
- Assessed the maturity and effectiveness of the compliance management system of several financial institutions, including some under a regulatory consent order. These bodies of work included an evaluation of the adequacy of compliance policies and strategies, risk assessment, monitoring and testing and management reporting.
- Managed Consent Order compliance tracking and correspondence on behalf of a federal financial services regulator.
- Led and performed the execution of consumer remediation efforts as required under the terms of regulatory enforcement actions, including those that addressed marketing, fulfillment and servicing related to consumer financial products and vendor management.
- Designing workflow processes, implementation plans, testing plans, testing scripts, user acceptance testing protocols, and performing gap analyses to facilitate regulatory compliance
- Performed internal compliance audits and reviews of lending and deposit operations for multiple banks and non-bank financial institutions
AREAS OF EXPERTISE
- Consumer Protection
- Compliance Program Design and Assessment
- Compliance Risk Identification and Management
- Compliance Audit and Testing
- Complaints Management
- RegTech for Financial Services
- FinTech for Consumer Financial Services
- Regulatory Relationship Management
- Consumer Financial Services
- JD – Howard University School of Law
- B.B.A. – Finance, Howard University
PROFESSIONAL MEMBERSHIPS & CERTIFICATIONS
- Certified Regulatory Compliance Manager (CRCM)
- Consumer Financial Services Committee, American Bar Association
- Licensed Attorney, State of New York