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
Three Hot CRA Concerns
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, […]
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!
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 […]
Do These Activities Qualify for CRA Credits?
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 […]
CRA Thresholds Announced for 2020
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 […]
CRA Public File Is No April Fools’ Joke!
April 1st is known as April Fools’ day, a time to play tricks and pranks. Some historians have noted that April Fools’ Day dates to 1582. It is speculated that the start of the new year had moved to January 1st and people who were slow to get the news and/or continued celebrating the new […]
CRA Asset-size Thresholds Announced for 2019
The annual CRA asset-size thresholds for covered financial institutions were announced on December 20, 2018 applicable for 2019. 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 2.59% increase in the CPI, the […]
