Bringing you a visual representation of your lending activity to help you uncover potentially discriminatory lending patterns.
We help you manage your CRA and Fair Lending risk by mapping your loan activity, identifying areas of gaps and related risk, and determining your loan penetration within underserved and minority communities in your market area.
Subtle changes in demographics and minority populations within your market area may go unnoticed, especially if your bank has expanded into new regions.
Failing to analyze and understand such changes, not understanding residents’ credit needs, and offering loan products unsuitable for the population can open you to risks.
You don’t want to be that bank and suffer reputational and financial harm because of a knowledge gap. Not understanding your banks’ lending patterns within your market area and inadequate marketing and outreach efforts could inadvertently lead to discriminatory lending practices.
We bring you the tools and talent to allow you to visualize your loan activity and show how you can adjust it accordingly.
Using mapping software, we provide a visual picture of your lending patterns and demonstrate neighborhoods or communities that may have been excluded or have limited lending activity.
By incorporating your lending data — loan applications, originations, and denials — we uncover your bank’s lending trends and gaps and pinpoint unseen biases.
After our analysis, you have a complete picture of your lending area and patterns, insight into whether your lending practices are sufficient, and strategies to improve credit access.
TCA gives you A Better Way to map your loan activity and accurately plan how to address your community’s credit needs.
Key deliverables include:
- Providing maps to allow you to make more intelligent and strategic lending decisions
- Helping you identify and proactively respond to population shifts in your market areas
- Identifying areas where residents face unequal access to credit
- Guiding you in enhancing your lending outreach and effectively meeting the credit needs of underserved communities and people from low-to-moderate income and minority backgrounds
Additional Fair Lending Topics
Mitigate Risk: Understand Your Lending Patterns
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan […]
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
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 […]
