
Scott Cummings, CRCM, CERP, CFE, CIA
Managing Examiner

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About me
CRCM, CIA, and CFE with experience in Internal Audit, External (Regulatory) Audit, Operational and Compliance Risk Management, Internal Controls, and 2nd Line Compliance Testing in Banking and Insurance.
Education

Illinois Wesleyan University
1983 - 1986Bachelor of Science (BS) Accounting
Experience

Illinois Department of Insurance
Feb 1986 - Jul 2002Managing ExaminerAudited Insurance Companies for financial solvency, as well as complaince with Illinois Insurance Regulations.

The Warranty Group
Jul 2004 - Dec 2006Senior SOX ConsultantPerformed SOX Audits of various subsidiaries, and worked with subsidiaries to insure SOX compliance.

TAP Pharmaceuticals
Dec 2006 - Jan 2008Manager Ethics & CompliancePerformed Drug Price Reporting Audits, created Audit program for Grant Management System.

Greenlee Textron
Feb 2008 - Sept 2008Internal Controls ManagerResponsible for SOX Compliance for a manufacturing company with $500 million in sales, multiple locations throughout the US. Updated risk matrix, coordinated testing, implemented new more comprehensive testing schedule, reported results to Textron Corporate.

Noble Consulting
Oct 2008 - Sept 2009Senior ConsultantLead consultant/auditor on Insurance Company Regulatory Audits. Audits performed on a Risk Based approach, similiar in scope and nature to SOX audits and SAS 70's.

Cummings Coachwerks, LLC
Oct 2009 - Dec 2012OwnerPrivate transportation company providing Executive Level Service to clients via an exclusive arrangement with Windy City Limousines, Inc.

Accountemps
Oct 2012 - Nov 2012ConsultantCurrently on assignment with JPMorganChase performing Audit Consutling Services in the Commercial Card Business Unit.

Sears Holdings Corporation
Dec 2012 - Sept 2014Spearheaded a team of 6 auditors across the country in auditing and inventory management of Sears and Kmart stores. Performed Sarbanes-Oxley planning, testing and reporting for inventory, payroll and income taxes. Standardized reporting procedures for increased efficiency. Saved the company $3.5M during an audit of California sales tax calculations. Pulled $6M from stores into corporate cash accounts through detailed review of best practices for in-store cash balances. Minimized completion time of audits, expanded store coverage and delivered real time results through establishing new store audit plan. Show less
Manager of Internal Audit
Aug 2013 - Sept 2014Senior Corporate Auditor
Dec 2012 - Aug 2013

Lundbeck
Oct 2014 - May 2017Manage expense reporting and auditing of over 950 employees, including customer service and providing inquiry responses. Audited all facets of Procure to Pay Process including accounts receivable, payroll and treasury departments for policy compliance, best practices and Sarbanes-Oxley Compliance; established process flows and narratives, risk matrices and control gap analysis as well as creating and implementing testing plans, providing results reporting with actionable recommendations. Collaborate with internal audit teams as well as external audit teams for planning and testing. Communicate with compliance team to adhere to Sunshine Act Reporting. Executed duplicate payment audits, recovering $3M, facilitating improvements through suggesting new controls. Spearheaded implementation of Concur Travel System and upgrade of Concur Expense System whilst cultivating a relationship between commercial operations and finance departments. Show less
Accounting Compliance Manager (Internal Audit Manager)
Jan 2016 - May 2017Senior Accounting Operations Analyst (Sr. Internal Auditor)
Oct 2014 - Dec 2015

Discover Financial Services
May 2017 - May 2018Manager, Business Risk and Internal Controls• Conducted Risk and Control Self Assessments, proposing new risks and controls as needed, contributing to enhanced risk management strategies• Facilitated communication between Home Equity Business and Audit/Compliance, assisting with audit planning, documentation gathering, and reviewing control mapping to operational and compliance risks • Created Process Flows for end to end Home Equity Process

HSBC
May 2018 - May 2019AVP, Senior Compliance Control Officer• Conducted Regulatory Compliance Testing, independently assessing controls' effectiveness in mitigating compliance risks, completing assigned testing ahead of schedule, typically within 2.5 - 3 months, surpassing the 4-month timeline• Performed first-line testing review, developed independent testing protocols, identified control gaps, and reported findings to management

Discover Financial Services
Jun 2019 - Jul 2024• Reviewed 2,500 vendors (consultants, IT services, software providers, HR, & printing services) to past validate Inherent Risk Assessments, updating 14 assessments accordingly• Created and executed plan to consolidate Vendor Resiliency from 5 departments into a single TPRM team, enhancing risk management, efficiency, and collaboration with internal BC team for improved outage preparedness• Led data collection project for 135 vendors to enter missing RTO, RPO, and SLA data into system for Critical and High-Risk engagements, collaborating with vendor relationship owners, and implemented ongoing monitoring for improved risk management• Drafted procedures and step-by-step job aids for the new TPRM Vendor Resiliency department, detailing processes for effective challenge of IRA, exit strategy, engagement risk assessments, and contract deviation reviewsCreating a team to focus on Third Party Resiliency Risk and related Mitigations. Show less ● Led Exam Coordination for CFPB Fair Lending Exam, managing submission of 38M credit card transaction records, including applications, charges, payments, and credits, ensuring all results were submitted on time● Created and managed an Enterprise-Wide Testing Calendar for 10 business units, including Card, Business Technology, Consumer Bank, and Payments, streamlining resource planning for regulatory exams, internal audits, and first and second-line testing● Created and delivered quarterly "Staying Ahead in Regulatory Space" presentations for up to 200 VPs, Directors, and Senior Managers, enabling proactive project adjustments for compliance based on regulatory discussions and public issues affecting other banks● Managed CFPB-requested review of 1.5M records, including credit card payment histories and call logs, to ensure equitable treatment of customers using COVID-19 programs Show less • Project managed 160 concurrent issues for Card Collections Value Stream, addressing procedural non-compliance, inadequate procedures, and system limitations, leading to defined root causes, action plans, and significant improvements in efficiency, effectiveness, and customer satisfaction• Performed annual Risk & Control Assessments for both Operational and Compliance Risks to determine that all Risks has effective controls in place• Crafted an EUC (End User Computing) procedure for US Cards to track EUCs, including an annual effective challenge to verify risk levels accuracy, ensuring appropriate controls and optimizing resource allocation based on risk• Reviewed 200 operational and compliance risks, ensuring all were properly mapped to controls, following COSO guidance to confirm all risks were mitigated according to US credit card industry regulations Show less
Principle - Third Party Risk Management- Vendor Resiliency
Jan 2024 - Jul 2024Senior Manager - Exam Management
Jun 2021 - Jan 2024Manager, Business Risk and Controls
Jun 2019 - Jun 2021

Professional Chauffeur Training Institute
May 2022 - nowTraining Manager• Conduct classroom instruction for individuals preparing for the Chicago Chauffeur License Exam.• Updated training materials regularly to ensure compliance with current regulations.• Implemented interactive teaching methods to enhance student engagement and retention.

Concora Credit
Jul 2024 - Jan 2025Compliance Manager• Provided Compliance Guidance/Advisory for project to allow customers to make account payments with their Debit Card via the Phone System and Mobile App• Provided Training with guidance as to which regulation is applicable to each training course• Reviewed Complaints to determine if there were could be any Fair Lending / UDAAP concerns• Provided Compliance Guidance/Advisory for a new program to allow past due accounts to be re-aged if certain payment criteria were met.
Licenses & Certifications
- View certificate

Certified Regulatory Compliance Manager (CRCM)
American Bankers AssociationJun 2023 - View certificate

Certified Internal Auditor (CIA)
The Institute of Internal Auditors Inc.Nov 2007 
Certified Enterprise Risk Professional
American Bankers AssociationApr 2024.webp)
Certified Fraud Examiner (CFE)
Association of Certified Fraud Examiners (ACFE)Sept 2018
Volunteer Experience
Board Member / Secretary
Issued by 12 Oaks Condo Association on Mar 2016
Associated with Scott Cummings, CRCM, CERP, CFE, CIAManager
Issued by Holy Innocents Food Pantry on Feb 2010
Associated with Scott Cummings, CRCM, CERP, CFE, CIAFinance Team Lead
Issued by St. Nicholas Episcopal Church on Dec 2017
Associated with Scott Cummings, CRCM, CERP, CFE, CIA
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