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
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 […]
Three Hot CRA Concerns
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs, […]
Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!
As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small […]
Do These Activities Qualify for CRA Credits?
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 […]
CRA Thresholds Announced for 2020
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 […]
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