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
Additional Fair Lending Topics
Executive Order on Disparate impact and What a Bank Should Know
On April 23, 2025, an Executive Order regarding Disparate Impact was issued. The Order states: “It is the policy of the United States to eliminate the use of disparate-impact liability in all contexts to the maximum degree possible.” In addition, it requires the assessment of pending investigations and litigation to extend to the Department of […]
What are MDI’s and the benefits of partnering with one?
Do you ever feel hesitant to engage with organizations in your community because you are unsure if the activity will qualify for CRA? You are not alone. Inconsistencies among the agencies as to what qualifies as CRA eligible activity can cause confusion and make discerning worthwhile partnerships from not-so-worthwhile partnerships that much more difficult. In […]
CRA In the Boardroom
As financial institutions face increasing pressure to demonstrate their commitment for economic stability in underserved areas and populations, the responsibility of the Board of Directors under the Community Reinvestment Act (CRA) has never been more critical in shaping strategies that serve both community and business interests. TCA – A Better Way!
TCA Compliance Welcomes Sara Kirkpatrick, Enhances its CRA Expertise
With the hiring of Sara Kirkpatrick,TCA Compliance is enhancing the consulting it provides to banks on CRA compliance topics. TCA Compliance is a full-service company that provides A Better Way for banks to manage their compliance obligations. Kirkpatrick brings firsthand knowledge of first-time homebuyers and CRA programs. She initially anticipated working at a non-profit or […]
Mitigate Risk: Understand Your Lending Patterns
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan […]
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
