Protiviti Contact

Protiviti Contact

Thomas S. Giltrow

Managing Director

Professional Experience

Tom is a Managing Director in Protiviti’s Risk and Compliance Practice, focused primarily on consumer compliance within the financial services industry. Prior to joining Protiviti, Tom attended Kalamazoo College, where he graduated summa cum laude with a Bachelor of Arts degree in Economics and Business and Spanish Language and Literature. Tom is also proficient in Spanish, and holds the CRCM certification.

Tom consults with financial service companies in managing all types of regulatory risk. Services range from high-level risk assessment and compliance process development to detailed file reviews and compliance audits. Tom has considerable experience advising internal audit functions on matters related to program design and planning and, in many cases, leads or otherwise advises on key compliance risks and industry best practices in the approach to and execution of compliance-related internal audits. Tom’s clients include multiple top ten national banks and other specialty financial services companies. Tom writes regularly on topics related to consumer protection legal and regulatory requirements and internal audit.

Major Projects

  • Led the review and risk assessment of multiple bank and consumer lenders’ fair lending compliance programs. Specifically, Tom conducts detailed comparative file reviews, performs statistical data analyses to identify apparent inherent fair lending risks and performs assessments of institutions’ fair lending-related policies, procedures, training, monitoring, reporting and internal controls.
  • Reviewed and/or provided consulting services regarding the adequacy of compliance functions for multiple top ten financial institutions and for one big ten university, including an evaluation of the risk assessment process and compliance review programs.
  • Served as the interim head of Compliance & BSA/AML audit for a global financial institution, during which Tom oversaw an audit team of 20 individuals and led the timely execution of all audits for which he was responsible, managed day to day relationships with multiple regulatory agencies, and represented the audit function on various executive-level committees.
  • Managed Protiviti’s compliance internal audit engagement with a top ten national Bank for four years, both advising on the scope of, arranging resources for and participating in client’s compliance audits. As part of this engagement, Tom also provided feedback on and assisted in the development of the Bank’s compliance internal audit plan, developed a methodology for vertical and horizontal audit approach, and mapped compliance audit coverage to assist the Bank in evaluating the completeness of audit coverage.
  • Led the execution of commercial, consumer and mortgage lending originations and servicing compliance audits for multiple national financial institutions, including a top ten national bank and several large regional banks. Tom typically leads management walkthroughs and transaction testing for detailed file reviews, including but not limited to, an assessment of compliance with TILA, RESPA, HPA, FDPA and Regulation B/ECOA requirements.
  • Led the assessment of an internet-based bank’s compliance with deposit regulations; specifically, FCRA, Regulation CC, Regulation D, Regulation DD and Regulation E. Tom was responsible for leading detailed file testing, reviewing disclosure content for accuracy and completeness and assessing the institutions’ policies, procedures and internal controls.

Areas of Expertise

  • Governance, Risk, and Compliance

Industry Experience

  • Financial Services


  • B.S. – Economics & Business, Spanish Language & Literature, Kalamazoo College

Professional Memberships & Certifications

  • Certified Regulatory Compliance Manager (CRCM)
  • Institute of Certified Bankers