Examinations are placing greater emphasis on data integrity, pricing disparities, marketing practices, and redlining indicators. TCA supports institutions throughout the examination cycle to reduce uncertainty, resolve examiner concerns, and promote stronger examination outcomes.
We provide hands-on support before, during, and after fair lending exams so your team is confident, prepared, and positioned to respond effectively to examiner inquiries and priorities.
Pre-Exam Preparation
TCA helps institutions prepare by:
- Reviewing historical lending data and risk indicators
- Pre-assessing marketing and outreach practices
- Evaluating pricing and underwriting variability
- Stress-testing potential examiner questions and findings
During the Examination
- TCA provides in-exam support, including:
- Assisting with data and documentation requests
- Assisting with responses to examiner inquiries
- Providing context and narrative explanations
- Supporting institution SMEs throughout the process
- Clarifying methodologies and risk interpretations
Post-Exam Follow-Up
Post-exam support includes:
- Evaluating examiner conclusions
- Reviewing MRA/MRIAs and observations
- Developing remediation plans
- Enhancing Fair Lending Program components
- Preparing management and board reporting
Benefits to Institutions
Institutions leverage TCA for:
- Increased confidence during regulatory engagement
- Reduced compliance and reputation risk
- Smoother examiner communication
- More efficient responses and faster resolution
Additional Fair Lending Topics
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 […]
