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
TCA Compliance Welcomes Sara Kirkpatrick, Enhances its CRA Expertise
With the hiring of Sara Kirkpatrick,TCA Compliance is enhancing the consulting it provides to banks on CRA compliance topics. TCA Compliance is a full-service company that provides A Better Way for banks to manage their compliance obligations. Kirkpatrick brings firsthand knowledge of first-time homebuyers and CRA programs. She initially anticipated working at a non-profit or […]
Mitigate Risk: Understand Your Lending Patterns
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan […]
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
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 […]
