Margaret Dolinger

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Mitigate Risk: Understand Your Lending Patterns

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 […]

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Fair Lending

Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs

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

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small business loan

Small Business Data Collection – Are You Having the Conversation?

By Margaret Dolinger, CRCM 1071 Dodd Frank requires financial institutions to collect data on small business loans and record them on a Small Business Lending Application Register. The Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule on October 8, 2021, regarding the covered institutions and covered transaction pursuant to proposed Regulation B 1002.101 –

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HMDA News and Census Tract Updates

Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated

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2022 Census Tracts Changes What it May Mean for Your Assessment Area

The 2020 Census data has been released by the US Census – and it may impact your Assessment Area for CRA and your Lending Area for Fair Lending. The Federal Financial Institutions Examination Council (FFIEC) which provides uniformity and consistency in the supervision of financial institutions, incorporates the US Census data in a format that

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A Refresh on Regulation B’s Special Purpose Credit Program

On April 26, 2022, Wolters Kluwer conducted a webinar “Special Purpose Credit Programs: Everything You Always Wanted to Know”. The speakers included: Patrice Ficklin, Fair Lending Director of the Consumer Financial Protection Bureau Pamela Perry, Vice President, Single-Family Equitable Housing, Freddie Mac Kenneth Scott, Citibank Anand Raman, Skadden Arps The speakers discussed the credit needs

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UDAAP

CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices

The Consumer Financial Protection Bureau (CFPB) announced on March 16, 2022, the added scrutiny of illegal discriminatory practices within its examination procedures for Unfair, Deceptive, Abusive Acts and Practices (UDAAP). The CFPB considers that illegal discrimination practices based on services or products can cause consumer harm; therefore, UDAAP should be included with the other Fair

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Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

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800-934-REGS

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[email protected]

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2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

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