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
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 […]
OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet?
If your institution is regulated by the FDIC or FRB, you can stop reading here, unless you want to see what could be coming your way in the near future. The OCC published a final Community Reinvestment Act rule on June 5, 2020 which marks a departure from the OCC, FDIC and FRB being “in […]
