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
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 …
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 …
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 …
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 …
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) …