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
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 […]
Submit Comments to CRA Modernization Initiative
Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC) […]
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