Independent Fair Lending Audits

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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

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FFIEC Releases 2019 CRA Public Data Tables

By | December 17, 2020

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 […]

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OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet?

By , | December 9, 2020

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 […]

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Three Hot CRA Concerns

By | October 20, 2020

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, […]

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Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!

By | May 28, 2020

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 […]

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Do These Activities Qualify for CRA Credits?

By | May 22, 2020

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 […]

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CRA Thresholds Announced for 2020

By | December 31, 2019

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 […]

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

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