Fair lending expectations continue to intensify. Regulators are applying increased scrutiny to governance, monitoring practices, data analysis, redlining indicators, and consumer outcomes. TCA’s Fair Lending Performance & Program Review provides institutions with an objective assessment of program maturity, risk exposure, and alignment with current agency expectations.
We help you objectively assess the maturity, effectiveness, and regulatory alignment of your fair lending and CRA programs to uncover risk, strengthen controls, and prepare for heightened examiner scrutiny.
What Our Review Covers
TCA evaluates both quantitative and qualitative elements, including:
- Governance & oversight structures
- Policy and procedure alignment
- Monitoring & testing frameworks
- Complaint and exception management
- Marketing and outreach practices
- Branch distribution & service delivery channels
- Training programs and role-specific accountability
Data-Driven Comparative Analysis
TCA conducts comparative analysis using:
- Peer and census demographics
- Lending penetration & redlining indicators
- Pricing and underwriting metrics
- Application and denial patterns
- Market and assessment area delineation
Our methodology mirrors regulatory expectations, helping institutions surface and resolve disparities before an exam.
Actionable Reporting
Our analysis includes:
- Clear narrative summaries
- Identified risk indicators
- Recommended mitigations
- Program enhancement opportunity suggestions
- Regulatory alignment considerations
- Mapping to visually support lending efforts
Reporting meets examiner expectations and improves examiner dialogue by demonstrating a proactive posture.
The TCA Difference
TCA brings insight into how agencies interpret data, how risk is weighted, and where institutions are most likely to encounter supervisory scrutiny.
Additional Fair Lending Topics
Executive Order on Disparate impact and What a Bank Should Know
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What are MDI’s and the benefits of partnering with one?
Do you ever feel hesitant to engage with organizations in your community because you are unsure if the activity will qualify for CRA? You are not alone. Inconsistencies among the agencies as to what qualifies as CRA eligible activity can cause confusion and make discerning worthwhile partnerships from not-so-worthwhile partnerships that much more difficult. In […]
CRA In the Boardroom
As financial institutions face increasing pressure to demonstrate their commitment for economic stability in underserved areas and populations, the responsibility of the Board of Directors under the Community Reinvestment Act (CRA) has never been more critical in shaping strategies that serve both community and business interests. TCA – A Better Way!
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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 […]
