Independent Fair Lending Audits
Independent Community Reinvestment Act Reviews
Mapping of Loan Activity
Fair Lending Performance/Program Review
Fair Lending Exam Assistance and Support
Non-Originated Loan Review and Analysis
Pricing Exception Tracking Analysis
Bringing you a strategy to satisfy your Fair Lending and CRA obligations and respond to your community’s needs.
We help you minimize your Fair Lending exposure with a formal, risk-based strategy.
Managing your Fair Lending requirements can carry immense risk because of the legal and ethical responsibilities associated with the regulations.
After all, your community looks to you to respond to its financial needs.
It's essential to understand your loan process and lending patterns within your market, given that regulators are signaling that they'll pay greater attention to fair lending and focus on diversity, equity, and inclusion.
If your team is stretched thin, we can help.
Our Fair Lending experts are skilled at understanding lending patterns, identifying areas of concern, and refocusing risk-based Fair Lending programs in advance of regulatory criticism and before consumers are harmed.
We examine your products, processes, and policies, along with your technology and training to identify weaknesses and provide insight on ways you may be underperforming based on your area’s demographics and peer group.
The thorough assessment helps you avoid common compliance dangers, whether they’re related to marketing and underwriting, your census tract, or consumer complaints.
As a result, you’re better equipped to develop a strategy appropriate to your bank’s risk and one that meets local needs and aligns with the nuances of your market area.
We also recommend best practices on adapting to the inevitable regulatory shifts that may affect your bank.
You can be confident that you have sound Fair Lending program and that you’re acting as a true partner with your community—doing your part to develop and revitalize it and improve the lives of its residents.
Managing your Community Reinvestment Act (CRA) requirements also is risky, and we perform an analysis of your program performance alongside our Fair Lending assessment.
Our approach to conducting CRA exam is identical to the one that regulatory agencies take.
After a comprehensive review, we leave you with a realistic appraisal of your CRA performance and confirm the accuracy of your assessment areas to help you minimize your exposure.
TCA shows you A Better Way to limit your Fair Lending and CRA risks and effectively serve the financial needs of your community.
Key Deliverables Include:
- Providing an accurate evaluation of your Fair Lending and CRA risks
- Analyzing your lending patterns and community involvement.
- Keeping management and executives abreast of the bank’s performance.
- Identifying strategies that better address your community’s credit needs.
- Providing training, so all employees, executives, and board members understand their responsibilities.
Fair Lending/CRA Insights
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 …
OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet? Read More »
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 …
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too! Read More »
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