Providing insight and guidance to help you demonstrate compliance with CRA regulatory requirements.
We provide expertise and impartiality to ensure an objective CRA review.
Meeting your community's credit needs is a regulatory requirement and a long-term benefit to your bank. It's good business.
After all, by collaborating with community groups and addressing the financial needs of low- to moderate-income residents and communities, you're playing a vital role in creating a healthy, thriving community that can only enhance your reputation as a solid community partner.
Meeting all the CRA requirements, from understanding complex regulations and proper data management to engaging with community organizations, can be time-consuming and challenging.
Non-compliance is a risky business that can result in serious repercussions, including reputational and regulatory punishment, as well as limiting the institution’s growth.
TCA is here to help you reach your goal of attaining at least a satisfactory rating on your next CRA examination. We use the same examination procedures developed and used by the regulatory agencies.
We take a deep look at all the elements of a sound CRA program, including your:
- CRA policies and procedures
- CRA-related lending data analytics and demographic distribution.
- Engagement with local community groups to understand the community needs.
- Community development lending, investment, and service activities.
Look to TCA for A Better Way to evaluate your CRA strategy and ensure that it serves your community and aligns with your community development goals.
Key deliverables include:
- Analyzing your lending to low-to-moderate individuals and locations
- Providing pointers on addressing current deficiencies and avoiding future ones
- Helping to evaluate current community needs and assist in developing a plan to address any program gaps
- Ensuring that you're maintaining the appropriate information to support the Banks’ history of meeting the community’s need
Additional Fair Lending Topics
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 – A Better Way!
April 1st is Fast Approaching: Did You Update Your CRA Public File?
April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your […]
CRA Asset-size Thresholds Announced for 2023
The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. 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. […]
FFIEC Releases 2020 CRA Public Data Tables
On December 21, 2021, the FFIEC released the public disclosures for CRA data submitted for calendar year 2020. 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 […]
Everything Old is New Again- OCC Rescinds CRA Rules
The OCC issued News Release 2021-133 on December 14, 2021, announcing the final rescinding of their June 2020 Community Reinvestment Act (CRA) Rule. The Final Rule will become effective as of January 1, 2022 and will apply to all national banks as well as to both federal and state savings associations. Financial institutions regulated by […]
