Providing insight and guidance to help you demonstrate compliance with CRA regulatory requirements.
We provide expertise and impartiality to ensure an objective CRA review.
Meeting your community's credit needs is a regulatory requirement and a long-term benefit to your bank. It's good business.
After all, by collaborating with community groups and addressing the financial needs of low- to moderate-income residents and communities, you're playing a vital role in creating a healthy, thriving community that can only enhance your reputation as a solid community partner.
Meeting all the CRA requirements, from understanding complex regulations and proper data management to engaging with community organizations, can be time-consuming and challenging.
Non-compliance is a risky business that can result in serious repercussions, including reputational and regulatory punishment, as well as limiting the institution’s growth.
TCA is here to help you reach your goal of attaining at least a satisfactory rating on your next CRA examination. We use the same examination procedures developed and used by the regulatory agencies.
We take a deep look at all the elements of a sound CRA program, including your:
- CRA policies and procedures
- CRA-related lending data analytics and demographic distribution.
- Engagement with local community groups to understand the community needs.
- Community development lending, investment, and service activities.
Look to TCA for A Better Way to evaluate your CRA strategy and ensure that it serves your community and aligns with your community development goals.
Key deliverables include:
- Analyzing your lending to low-to-moderate individuals and locations
- Providing pointers on addressing current deficiencies and avoiding future ones
- Helping to evaluate current community needs and assist in developing a plan to address any program gaps
- Ensuring that you're maintaining the appropriate information to support the Banks’ history of meeting the community’s need
Additional Fair Lending Topics
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 …
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. …
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 …
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? Read More »
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors …