Wells Fargo – Income Review Calculator for Loans (IRCL)

Client:
Wells Fargo
Date:
June 1, 2019
Categories:
Case Study
Tags:
OCC/CFPB-Aligned, Lending Systems, Full-Stack Engineering

The Income Review Calculator for Loans is one of the most consequential pieces of software in Wells Fargo's consumer lending operation. It determines customer eligibility across auto, mortgage, and personal loan products — decisions that affect millions of borrowers and must withstand scrutiny from both the OCC and the CFPB. Every calculation path must be traceable, every decision auditable, and every change documented to regulatory standards.

Sapot Systems supported this system across a two-year engagement with a team of five engineers, working in a zero-tolerance regulatory environment where an incorrect calculation isn't a bug to be fixed in the next sprint — it's a potential compliance event. The work covered calculation engine development across three lending product lines, OCC and CFPB-aligned logic review, and the implementation of a full audit trail for all income calculation decisions.

By the end of the engagement, manual review workload had been reduced by 40%, decision accuracy had improved across all three lending products, and the system could produce a complete audit trail for any calculation on demand.

Why this matters for federal work: OCC and CFPB compliance requirements for documentation, decision traceability, and regulatory audit readiness are a direct analog to federal financial and program management compliance obligations. Any agency that processes eligibility determinations, benefits calculations, or financial transactions under federal oversight faces similar requirements. This engagement is evidence that Sapot Systems can operate effectively in environments where the cost of a wrong answer is high.

Loan eligibility calculation engines built to withstand OCC and CFPB scrutiny.

Sapot Systems supported a mission-critical application used to determine customer eligibility across auto, mortgage, and personal loan products — one of the most heavily regulated financial environments in the United States. Calculation logic was aligned to OCC and CFPB expectations, with full auditability and traceability required on every decision path.

Engagement details: Team: 5 engineers · Duration: 2 years · Environment: OCC/CFPB-regulated

What we delivered:

  • Loan eligibility calculation engines across three lending product lines
  • OCC and CFPB-aligned calculation logic with full audit trail
  • Enhanced auditability and traceability of all income calculation decisions
  • Production-scale delivery in a zero-tolerance regulatory environment

Results:

  • 40% reduction in manual review workload
  • Improved decision accuracy across all lending products
  • Full auditability and traceability of income calculations

Relevance to federal: OCC and CFPB compliance requirements — documentation standards, decision traceability, and regulatory audit readiness — are a direct analog to federal financial and program management compliance obligations.