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
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 […]
