Margaret Dolinger

There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing […]

Much has happened since the beginning of 2018, especially in the world of HMDA. This is Part 3 in TCA’s series of HMDA articles. Part 1 focused on managing HMDA risk amid reporting uncertainty and Part 2 focused on HMDA reporting for purchased loans. One HMDA data collection change that has surfaced is causing headaches

Now that more than half the year is gone, many banks are starting to look more closely at their new 2018 HMDA LAR requirements because they have adequate volume to do testing. TCA wants to share with you what we have found in doing preliminary HMDA LAR validations. Many of the issues we’ve seen are

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want

The Community Reinvestment Act (CRA) celebrated its 40th anniversary in 2017. The Act was established to ensure banks were meeting the credit needs of the community they designated as their assessment or market area, which often was a circle around their branches. Passing a CRA exam was less troublesome since bankers only had to be