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)
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 […]
