Withdrawals, denials, and incomplete applications can be key indicators of increased fair lending risk. Examiners increasingly analyze non-originated application data to surface disparate treatment, pricing outliers, and steering concerns. TCA’s Non-Originated Loan Review evaluates patterns and root causes to help institutions mitigate risk before examiners arrive.
We help institutions identify risk and hidden patterns in non-originated loan portfolios so you can improve fair lending outcomes, validate decisioning practices, and support stronger compliance governance.
What We Analyze
Reviews may include:
- Application disposition patterns
- Pricing and underwriting consistency
- Counteroffer practices
- Communication timeliness and content
- HMDA data mapping
- Denial reason coding
- Customer interaction documentation
- Comparative analysis by prohibited basis group
Why It Matters
Regulators are asking deeper questions about:
- Who is applying
- Who is receiving approvals
- Why applications stop moving forward
- Whether certain groups experience barriers or delays
- Non-originated data often provides the clearest lens into potential disparate treatment risk.
Deliverables
TCA provides:
- Key findings and risk indicators
- Trend and variance analysis
- Root cause assessments
- Recommendations for control enhancements
- Board and management level reporting (optional)
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