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
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 …
April 1st is Fast Approaching: Did You Update Your CRA Public File? Read More »
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. …
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 …
Everything Old is New Again- OCC Rescinds CRA Rules Read More »
Is there any new fair lending risk that a financial institution should make sure is included in the Fair Lending Risk Assessment?
Answer: Yes. A new CFPB initiative has been developed known as PAVE – Property Appraisal and Valuation Equity. It is an Interagency Task Force to address inequity in home appraisals. Examiners will be looking to see how financial institutions ensure there is no appraisal bias in minority neighborhoods or minority homes by monitoring the financial …
Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms?
Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected …
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 …
