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
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 […]
FFIEC Releases 2019 CRA Public Data Tables
On December 14, 2020, the FFIEC released the public disclosures for CRA data submitted for calendar year 2019. 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 […]
