The University of Chicago Booth School of Business

University of Chicago

Columbia Engineering

Massachusetts Institute of Technology

University of Oxford

Stanford University Graduate School of Business

Northwestern University

Adjunct Professor

Direct regulatory compliance supervision strategy and implementation of a portfolio of large U.S. depository and non-depository financial institutions and large financial services technology providers.

Authored CFPB's Information Technology Compliance Management System field examinations procedures (CMS-IT).

Authored CFPB's field examinations guidance on statistical & non-statistical sampling of financial transactions for regulatory compliance testing.

Supervision strategy & field examinations cover the following markets:

- TECHNOLOGY
- MORTGAGES
- CARDS, PAYMENTS, REMITTANCES 
- DEPOSITS, LENDING & CREDIT REPORTING 
- INSTALLMENTS & COLLECTIONS
- SMALL BUSINESS LENDING

Consumer Financial Protection Bureau

Senior Regulatory Risk Management Executive

Part of a team of ~30 University of Chicago data scientists and analytics experts who developed a significant enhancement to IBM Watson's Cognitive Supply Chain Solution capabilities. The team developed an AI-enabled risk management solution that augments IBM's global supply chain disruptions proactive identification and response capabilities.

Michael's specific role:

Developed and deployed specific big data, artificial intelligence, and UI/UX modules.
Led all solution development communications with IBM Global Supply Chain team in Singapore in a SCRUM / [IBM Design Thinking] AI solutions development & deployment setting.

Note: This project is part of a multi-year collaboration initiative between IBM and The University of Chicago MS in Applied Data Science program.

Artificial Intelligence Solution Development & Deployment Consultant

Founder & Head of the Bureau’s National Information Systems Supervision Program (NISSP). Support CFPB enforcement actions and direct the strategy, design, and execution of examinations of IT systems affecting the following consumer financial markets: 

- MORTGAGE
- CARD, PAYMENTS, REMITTANCES 
- DEPOSITS, LENDING & CREDIT REPORTING 
- INSTALLMENT & COLLECTIONS
- SMALL BUSINESS LENDING

These IT examinations focus on the design, development, configuration, and deployment of IT systems affecting consumer financial products and services. One specific area of focus is how the output of IT systems affects compliance with Federal Consumer Financial Laws that resulted from the Dodd-Frank Act of July 2010, as well as the related CFPB rules including HMDA, TRID, RESPA, TILA, Fair Lending, and Mortgage Servicing Rules. 

Responsible for the quality, accuracy, and consistency of these IT examinations including the recommendations for corrective actions to financial institutions and service providers' Boards and Senior Management. Entities covered by these IT examinations include Large Banks, Non-Depository Institutions (Non-DI), and Significant Technology Services Providers (TSP)/Vendors.

From 2014 to 2018, represented the United States Bureau of Consumer Financial Protection on the Federal Financial Institutions Examination Council (FFIEC) IT Sub-Committee (ITS) and Cybersecurity & Critical Infrastructure Working Group (CCIWG). As such, I played an active role in the strategy, design and issuance of FFIEC (CFPB, Federal Reserve, FDIC, OCC, NCUA, and the 50 States, DC & PR) uniform IT supervisory guidance, including the Cybersecurity Assessment Tool (CAT) and the 11 FFIEC IT Examination Booklets included in the official FFIEC IT Examination Handbook. [  https://ithandbook.ffiec.gov/  ]

Head of CFPB National Information Systems Supervision Program (NISSP)

Responsible for the assessment of the overall system of internal controls within PNC Mortgage Bank. In charge of building and deploying an effective Internal Audit team that performed audits and issued value-added recommendations to PNC Bank Senior Leadership. These recommendations were communicated through internal audit reports, continuous risk monitoring memos, special projects reports, dashboards, and other executive communication means, to the audit committee, the regulators (OCC and Federal Reserve Board), the rating agencies (Fitch and S&P), the GSEs (Freddie Mac and Fannie Mae), the U.S. Government mortgage guarantors (FHA and VA), and other private investors.

Accomplishments include:
 
Established an effective mortgage banking Internal Audit function to cover the newly acquired PNC mortgage core and default servicing businesses with a portfolio of $150B in serviced mortgages, and the mortgage operations business with mortgage originations of $15B annually. The audit function was also effectively established to cover mortgage regulatory compliance, and mortgage technology (origination, servicing and other investors reporting systems). 

Ensured the effective execution and communication to regulators (OCC, and Federal Reserve) of the internal audit program put in place in response to the unprecedented mortgage foreclosure crisis. This included Internal Audit response to the OCC and Federal Reserve Consent Orders, as well as designing and implementing a framework for the mapping and transition of the mortgage crisis Consent Order items, and Dodd-Frank/CFPB requirements to an effective augmented on-going audit program.

PNC Financial Services Group - PNC Bank

Senior Vice President - Head of PNC Mortgage Bank Internal Audit

Led the redesign of the blue print of AES global commodities trading hedge strategy and accounting processes risk mitigation. Designed processes to ensure compliance with FAS 133 (particularly FAS 133 Par 28 & 29, EITF D-102, and DIG E7). Significantly improved the documentation of the Company’s commodity trading processes by leading the redesign of detailed process flows and streamlining internal controls for commodities and power Day Ahead Commitment Trades, Forward Trades, and OTC Swaps, as well as the related hedge accounting and OCI, A&L, and P&L reconciliations. 

Remediated AES’s Material Weakness related to US GAAP/FAS 133 accounting for energy generation and distribution derivative and embedded derivative contracts. Directed the implementation of the remediation program in China, Brazil, UK, Puerto Rico, and Mexico. Managed a global remediation team that covered 125 businesses located in 26 countries on 5 continents.

Led the Internal Control over Financial Reporting (ICFR) reassessment related to the Company’s August 2007 restatement. Directed the production of all related 10K/A Item 9A and 10Q/A Item 4 SEC disclosures, including the MW disclosures related to FAS 133, FAS 52, and the Company’s Legal Entities MW. Produced an online ICFR Risk Assessment and Internal Control Exception Evaluation course deployed to the Company’s 125 businesses in 26 countries. 

CFO of a 200 MW Power Generation Plant. Directed the power plant financial reporting, SAP and BPC implementations, including the conversion of all legacy system accounting records to SAP through the SAP FICO process. Coordinated the renegotiation with Institutional Investors of a $0.5 billion Non-Recourse Long Term Debt and redesigned the compliance process with the Note Purchase Agreement Debt Service Coverage Ratio (DSCR) requirements.

Managing Director

Directed the financial reporting controls evaluation, deficiencies aggregation and analysis, and produced related outputs and deliverables for Freddie Mac’s financial reporting risks & controls stakeholders including senior management, the Audit Committee, the Disclosures Committee, Internal Audit, External Reporting, and external auditors.

Managed a team of up to 35 Freddie Mac/E&Y/BearingPoint consultants/employees to produce process flows, narratives and control matrixes as part of Freddie Mac’s firm wide risk and control business processes documentation effort. Areas covered included: Liquidity & Contingency Portfolio, Retained Portfolio of Mortgage Backed Securities, Debt & Derivatives, Cash Window, Securitization, Guarantor Flow, Multi-family, and Corporate support.

Directed the 2005 evaluation of internal controls to meet SOX Section 404 compliance requirements. Evaluation included documenting conclusions supporting the assessment of the operational and design effectiveness of key controls, as well as summarizing the results/conclusions in reports for senior management using a good understanding of the relevant SEC, PCAOB, IIA, ISACA and AICPA requirements as they relate to Sarbanes Oxley.

Freddie Mac

Director - Internal Control

Directed staff of 22 including Managers, Financial Analysts, Contract Analysts and Senior Contract Analysts. Coordinated monthly closing process for the Public Services line of business ($1.3B) and assured compliance with GAAP, FAR, DCAA and SEC regulations.

Provided expert advice related to complex long term IT services contracts revenue recognition (SOP 81-1, EITF 00-21, SOP 97-2, SAB 104, and VSOE), SEC and SOX compliance matters. Advised Managing Directors, Vice Presidents, and Senior Vice Presidents on deal structuring matters and proposal issues relating to revenue recognition on complex system integration contracts. 

Coordinated audits and reviews leading to SEC filings with external auditors and actively participated in the 10K and 10Q pre-filing review process. Performed complex estimate-at-completion calculations on large system integration contracts and advised Managing Directors on financial management issues.

KPMG US

Assistant Division Controller - Public Services Division

Reviewed audit workpapers; supervised and performed financial audits, prepared management advisory comments. Prepared financial statements including footnotes and MD&A. Aided clients with SEC filings including 10Q, 10K, S1 and S3. Directed and trained audit teams in job functionalities including operational reviews and risk management strategies. Led the due diligence engagement during client acquisition of a subsidiary in France.

Michael Diarra CPA, CISA, CDPSE