In order to timely close its $163 Million asset securitization, Upstart needed to validate the accuracy of 19,000 over loan files in a matter of hours. Upstart turned to Christiana Trust who had partnered with VeriComply and applied its automated Verification Agent solution. The results, in 2 hours over 19,000 loans processed and verified with 100% accuracy and 100% automation and the delivery of the electronic originals to an electronic vault confirmed. The VeriComply dashboard provided real time access to the process and the repository provided watermarked loan file, audit history and Verification Certificate for future reference.

The Situation

Upstart needed to ensure timely delivery and verification of over 19,000 loan files being securitized in its Grantor Trust 2017-1 deal. Rather than use the “stare and compare” method of loan verification and manual confirmation of delivery to an electronic vault, Upstart engaged Christiana Trust who had partnered with VeriComply. This partnership enabled Christiana and VeriComply to quickly execute the required VeriCompliance Process set up and seamlessly perform the file validation process flow.

The Challenge

The VeriComply team was faced with the challenge of setting up a process flow in a few days to provide a 100% validation (rather than a sampling) of over 19,000 loans confirming that:

  • Each Loan File contained a Promissory Note and a TILA disclosure.
  • The Loans listed in the Data Tape had corresponding documents in the Loan File.
  • The Loan Files had been successfully transmitted to the required electronic vault.

Additional requirements included providing evidence of compliance with rigorous data privacy and security requirements, a complete audit history of all work performed, a document repository for the verified loan files and an automated process to remove loan files from the system upon subsequent sale, payoff or charge off of the loan.

The Solution

The VeriComply team working with Upstart and Christiana was able to meet all these requirements on time and on budget. Here is how it happened:

Set Up Process:

  • Customized process flow designed and deployed in days.
  • Satisfied requirements of the Custodial Agreement.
  • Implemented using VeriComply’s Configuration Templates and Implementation Protocols.
  • Released in accordance with VeriComply’s Operation Qualification Protocol

VeriComply Process Flow:

  • Documents uploaded by secure FTP.
  • Process performed in less than an one hour on 100% of Loan Files.
  • Any exceptions reviewed by Christiana using the VeriComply workflow manager.
  • VeriComply Process audit history available in Project History folder of Repository.
  • A complete record of all exception workflows created.
  • In Process and Final Quality Checks performed.
  • Watermarking with VeriComply Logo and Logo ID on each document in each Loan File.
  • Report automatically populated with verified data and distributed to deal team.

The Results

Using state of the art technology, industry know and compliant Implementation Protocols, VeriComply handled all processing with minimal effort by Christiana Trust and provide Christiana Trust and upstart with:

  • Speed and Capacity– Over 19,000 loans processed in 1 hours .
  • Accuracy- 100% of loans validated with 100% automation and all exceptions verified manually in minutes.
  • Compliance– SSAE16 compliant process that protected Personally Identifiable Information.
  • Performance– Azure computing power “ramped” for peak performance and then reduced to save costs.
  • Timely Deal Close- deal closed on time with ability to verify the delivery of the Loan Files to an electronic repository.
  • Removal of Loans- system implemented to remove individual loans that are charged off, paid off or sold from the Repository.