On April 23, 2025, an Executive Order regarding Disparate Impact was issued. The Order states: “It is the policy of the United States to eliminate the use of disparate-impact liability in all contexts to the maximum degree possible.” In addition, it requires the assessment of pending investigations and litigation to extend to the Department of […]
Executive Order on Disparate impact and What a Bank Should Know Read More »
TCA often helps financial institutions review commercial loans for Regulation B compliance, which includes handling adverse action loan applications. During these reviews, TCA sees numerous mistakes, such as: TCA – A Better Way!
At TCA, we’ve already been fielding calls from clients confused about gross revenue under 1071. It is a key factor when identifying small business loans for the count of originations for the prior two years. Under 1071, a small business is defined as one with a gross revenue of $5 million or less. Financial institutions
When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital. The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The
1071 Preparation Guide | Article 4 Identifying and Counting Covered Transactions Read More »
We all knew more guidance on 1071 Dodd-Frank on Small Business Data Collection was coming. On May 17, 2024, the Consumer Financial Protection Bureau (CFPB) announced an interim final rule extending the compliance dates for data collection and data reporting for financial institutions. The Rule requires financial institutions to collect and report small business lending
1071 Preparation Guide – Article 1 Getting Started and Best Practices Read More »
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan
Mitigate Risk: Understand Your Lending Patterns Read More »
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs Read More »
2024 is right around the corner and there are a few provisions everyone needs to keep on their agenda to ensure compliance with the new CRA rules finalized on October 24, 2023. In an effort to help clarify the new rules, TCA reached out to the FDIC in Washington DC. The result of this call
New CRA Provisions Effective as of April 1, 2024 Read More »
Due to recent events overseas, there has been recent deployment of US troops with potential additional deployment to happen in the future. Interest rates are higher than they have been in the past; the current Prime Rate is at 8.5%. All financial institutions should be prepared for Servicemembers enacting their rights under the Servicemembers Civil
Deployment of Servicemembers Read More »
We’re here to review your current compliance strategy and help you find A Better Way to manage risk.
