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
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 […]
OCC Updated Addresses for Equal Housing, CRA and Adverse Actions
If you are not regulated by the OCC, then you can skip to the end of this Special Release. If you are regulated by the OCC, then you need to know the OCC issued Bulletin 2021-35 on August 5, 2021 updating addresses used for the Equal Housing Lender lobby posters, CRA lobby notices for the […]
OCC’s CRA June 2020 Final Rule – Maybe
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 […]
CRA Public File Reminder
April 1st is known as April Fools’ day and a time to play tricks and pranks. But did you know on April 1, 1748, the Ruins of Pompeii were rediscovered by Spaniard Rocque Joaquin de Alcubierre? Guess it is time to rediscover the CRA Public File and make sure nothing ancient is inside! By now […]
CRA Asset-size Thresholds Announced for 2021
The annual CRA asset-size thresholds for covered financial institutions were announced December 17, 2020 applicable for 2021. 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. As a result of the 1.29% increase in the CPI, the levels […]
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