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
Three Hot CRA Concerns
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs, […]
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!
As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small […]
Do These Activities Qualify for CRA Credits?
COVID-19 has caused nationwide turmoil, including in the financial services industry. Banks have been flooded with inquiries regarding deferral of payments, modification of loan provisions and loan requests to keep businesses afloat. Many banks have asked TCA whether certain activities would be considered as CRA credits or qualified community development activities. The first of many […]
CRA Thresholds Announced for 2020
The annual CRA asset-size thresholds for covered financial institutions were announced on December 30, 2019 applicable for 2020. 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 1.62% increase in the CPI, the […]
CRA Public File Is No April Fools’ Joke!
April 1st is known as April Fools’ day, a time to play tricks and pranks. Some historians have noted that April Fools’ Day dates to 1582. It is speculated that the start of the new year had moved to January 1st and people who were slow to get the news and/or continued celebrating the new […]
CRA Asset-size Thresholds Announced for 2019
The annual CRA asset-size thresholds for covered financial institutions were announced on December 20, 2018 applicable for 2019. 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 2.59% increase in the CPI, the […]
