Counterparty Due Diligence

Operational due diligence on the RTL, non-QM, and DSCR lenders you fund or buy from.

Warehouse lenders, investors, and banks engage Garrett, McAuley & Co. to review the operations of the lenders they do business with. We built our FOCIS Review for agency lending and adapt it to RTL, bridge, non-QM, and DSCR platforms. Each report fits that company's business model, not a generic template.

Advising lenders since
2003
Mortgage companies served
600+
Banks and thrifts served
120+
Reviews a year
40 to 60

What the review covers

  • Financial condition: leverage, liquidity, breakeven, warehouse covenants, and peer comparison
  • Operations: underwriting, QC, post-closing, closing and funding controls, and vendor oversight
  • Compliance: compliance management, examinations, AML/BSA, fair lending, and HMDA where it applies
  • Interest rate risk: pricing margins, hedging, pipeline coverage, and investor concentration
  • Systems and servicing: technology, business continuity, servicing, and subservicer oversight
  • For RTL and bridge lenders: construction draws, interest reserves, extensions, borrower entities, and sponsor concentration
  • For non-QM and DSCR lenders: alternative documentation, business-purpose licensing, and DSCR underwriting

How it works

  1. 1A call about the company, your concerns, and the scope you need.
  2. 2An information request and questionnaire sent to the company.
  3. 3On-site fieldwork with management and the staff who run the operation.
  4. 4A written report with scores, observations, and recommendations, typically within two weeks.

Talk with us about what you need.

A 30-minute call is the fastest way to see whether we are a fit. No cost, no obligation.

What you receive

  • A written report organized by discipline, with each observation rated by severity
  • A risk score for each discipline and a composite rating for the company
  • A report prepared solely for you, the engaging party
  • Delivery typically within two weeks of fieldwork

Why Garrett, McAuley

  • Principal-led: the person who interviews management writes the report
  • On-site fieldwork that walks the cash process with the people who run it
  • Results benchmarked against national peer data and the companies we review each year

Who you will work with

  • Joe Garrett

    Joe Garrett

    Co-Founder & Principal

    Joe Garrett has worked in banking and mortgage banking since 1977, mostly in FDIC-insured and OCC-regulated banks. He served on the boards of four banking institutions and as Chairman and CEO of two of them.

    LinkedIn
  • Michael D. McAuley

    Michael D. McAuley

    Co-Founder & Principal

    Michael D. McAuley became a commercial banker in 1984, specializing in mortgage warehouse lending and commercial lending. He managed the warehouse lending business for Washington Mutual and JPMorgan Chase, and he has helped commercial banks set up, assess, and improve their warehouse lending operations.

    LinkedIn
  • Steve Stone

    Steve Stone

    Managing Director

    Steve Stone has spent his career in independent mortgage banking, as an entrepreneur and as a senior operating executive. He founded and later sold an independent mortgage banking company, and he has managed loan production, servicing, secondary marketing, MSR strategy, and technology.

    LinkedIn

Common questions

How is this different from your warehouse lender reviews?
It uses the same FOCIS framework. For RTL, non-QM, and DSCR lenders, we add procedures for those business models and remove the ones that do not apply.
Do you go on site?
Yes. For RTL platforms, we sit with origination, servicing, and draw administration staff to see how they manage loans day to day.
Who receives the report?
You do. We prepare the report for the engaging party and do not share it with the company we review.
Can you review a lender before we approve a line or buy its loans?
Yes. Warehouse lenders and investors use these reviews at onboarding and again each year.

Send us a request

Tell us a little about your company and what you need. We reply within one business day.

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Last updated November 4, 2026