Specialties
Fair Lending Performance/Program Review
Fair Lending Exam Assistance and Support
Non-Originated Loan Review and Analysis
Pricing Exception Tracking Analysis
Bringing you a strategy to satisfy your Fair Lending and CRA obligations and respond to your community’s needs.
We help you minimize your Fair Lending exposure with a formal, risk-based strategy.
Managing your Fair Lending requirements can carry immense risk because of the legal and ethical responsibilities associated with the regulations.
After all, your community looks to you to respond to its financial needs.
It's essential to understand your loan process and lending patterns within your market, given that regulators are signaling that they'll pay greater attention to fair lending and focus on diversity, equity, and inclusion.
If your team is stretched thin, we can help.
Our Fair Lending experts are skilled at understanding lending patterns, identifying areas of concern, and refocusing risk-based Fair Lending programs in advance of regulatory criticism and before consumers are harmed.
We examine your products, processes, and policies, along with your technology and training to identify weaknesses and provide insight on ways you may be underperforming based on your area’s demographics and peer group.
The thorough assessment helps you avoid common compliance dangers, whether they’re related to marketing and underwriting, your census tract, or consumer complaints.
As a result, you’re better equipped to develop a strategy appropriate to your bank’s risk and one that meets local needs and aligns with the nuances of your market area.
We also recommend best practices on adapting to the inevitable regulatory shifts that may affect your bank.
You can be confident that you have sound Fair Lending program and that you’re acting as a true partner with your community—doing your part to develop and revitalize it and improve the lives of its residents.
Managing your Community Reinvestment Act (CRA) requirements also is risky, and we perform an analysis of your program performance alongside our Fair Lending assessment.
Our approach to conducting CRA exam is identical to the one that regulatory agencies take.
After a comprehensive review, we leave you with a realistic appraisal of your CRA performance and confirm the accuracy of your assessment areas to help you minimize your exposure.
TCA shows you A Better Way to limit your Fair Lending and CRA risks and effectively serve the financial needs of your community.
Key Deliverables Include:
- Providing an accurate evaluation of your Fair Lending and CRA risks
- Analyzing your lending patterns and community involvement.
- Keeping management and executives abreast of the bank’s performance.
- Identifying strategies that better address your community’s credit needs.
- Providing training, so all employees, executives, and board members understand their responsibilities.
Fair Lending/CRA Insights
April 1st is Fast Approaching: Did You Update Your CRA Public File?
April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your […]
CRA Asset-size Thresholds Announced for 2023
The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. […]
FFIEC Releases 2020 CRA Public Data Tables
On December 21, 2021, the FFIEC released the public disclosures for CRA data submitted for calendar year 2020. Note: If your institution does not report CRA small business, small farm or community development lending data, then this Special Release would not apply to you. Even if your institution is not a CRA reporter, a review […]
Everything Old is New Again- OCC Rescinds CRA Rules
The OCC issued News Release 2021-133 on December 14, 2021, announcing the final rescinding of their June 2020 Community Reinvestment Act (CRA) Rule. The Final Rule will become effective as of January 1, 2022 and will apply to all national banks as well as to both federal and state savings associations. Financial institutions regulated by […]
Is there any new fair lending risk that a financial institution should make sure is included in the Fair Lending Risk Assessment?
Answer: Yes. A new CFPB initiative has been developed known as PAVE – Property Appraisal and Valuation Equity. It is an Interagency Task Force to address inequity in home appraisals. Examiners will be looking to see how financial institutions ensure there is no appraisal bias in minority neighborhoods or minority homes by monitoring the financial […]
Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms?
Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected […]
