Navigating the complexities of Fair Lending regulations and helping your bank develop and maintain fair and diverse lending practices
We help you measure how well you adhere to Fair Lending laws and regulations and whether your policies, procedures, and practices provide equal and fair access to credit throughout your community.
Fair lending audits are not only a compliance requirement, but they assure you and your community that your lending policies are inclusive and that you treat everyone fairly. They’re essential ingredients in maintaining a solid reputation and enhancing community relations.
Still, banks can inadvertently make mistakes when working with borrowers and vetting their creditworthiness. A blip anywhere in the process can raise the stakes and result in financial penalties, regulatory punishment, and reputational damage.
We guide you in building a program that helps manage the fair lending risk and mitigates even unintentionally disparate treatment.
Our team has extensive experience and insight into Fair Lending laws and understands the finer points of regulatory requirements and changes. That knowledge allows us to help you mitigate risk and better manage your Fair Lending obligations.
We focus on the risk categories outlined within the Interagency Fair Lending Examination Procedures to identify potential violations and vulnerabilities. That includes a review of:
- Fair lending compliance management program
- Comparative loan file
- Policies and procedures established to manage fair lending risk
- Assessment of underwriting guidelines
- Lending pattern identification and data analysis at both the individual borrower characteristics level and the minority tract level
- Demographic makeup of the lending area
- Mapping of lending patterns in the Banks’ defined market area
TCA guides you to A Better Way to comply with Fair Lending regulations and continue providing equal access to credit in your community.
Key deliverables include:
- Evaluating your Fair Lending practices at the Board level and across bank departments
- Providing sophisticated analysis to identify your lending performance, identifying any deficiencies, and making recommendations for preventing discriminatory practices
- Helping you to maintain the bank’s standing in the community.
- Assessing your Fair Lending risk level
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 […]
