Pricing exceptions continue to be a focal point for regulators evaluating fair lending risk. Discretionary pricing, exception authority, and inconsistent documentation can produce disparities even when policies are neutral. TCA helps institutions strengthen exception tracking, monitoring, and reporting to reduce regulatory, compliance, and reputation risk.
We provide rigorous pricing exception tracking and analysis to help you uncover disparities, support defensible decisions, and strengthen your pricing governance and fair lending posture.
Key Areas of Review
TCA evaluates:
- Exception authority and escalation
- Approval and override practices
- Documented rationales
- Training and accountability
- Monitoring and periodic testing
- Compensation structures
- Pricing matrices and fee schedules
Analytical Components
Pricing exception analysis may incorporate:
- Comparative prohibited basis group testing
- Statistical variance analysis
- Peer and market benchmarking
- Trend analysis over time
- Outlier investigations
- Root cause assessments
Enhancing Program Controls
TCA provides actionable recommendations to strengthen:
- Exception logging and tracking
- Governance and documentation
- Reporting for management and the board
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