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
OCC Updated Addresses for Equal Housing, CRA and Adverse Actions
If you are not regulated by the OCC, then you can skip to the end of this Special Release. If you are regulated by the OCC, then you need to know the OCC issued Bulletin 2021-35 on August 5, 2021 updating addresses used for the Equal Housing Lender lobby posters, CRA lobby notices for the […]
OCC’s CRA June 2020 Final Rule – Maybe
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors […]
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 […]
