Navigating the complexities of Fair Lending regulations and helping your bank develop and maintain fair and diverse lending practices
We help you measure how well you adhere to Fair Lending laws and regulations and whether your policies, procedures, and practices provide equal and fair access to credit throughout your community.
Fair lending audits are not only a compliance requirement, but they assure you and your community that your lending policies are inclusive and that you treat everyone fairly. They’re essential ingredients in maintaining a solid reputation and enhancing community relations.
Still, banks can inadvertently make mistakes when working with borrowers and vetting their creditworthiness. A blip anywhere in the process can raise the stakes and result in financial penalties, regulatory punishment, and reputational damage.
We guide you in building a program that helps manage the fair lending risk and mitigates even unintentionally disparate treatment.
Our team has extensive experience and insight into Fair Lending laws and understands the finer points of regulatory requirements and changes. That knowledge allows us to help you mitigate risk and better manage your Fair Lending obligations.
We focus on the risk categories outlined within the Interagency Fair Lending Examination Procedures to identify potential violations and vulnerabilities. That includes a review of:
- Fair lending compliance management program
- Comparative loan file
- Policies and procedures established to manage fair lending risk
- Assessment of underwriting guidelines
- Lending pattern identification and data analysis at both the individual borrower characteristics level and the minority tract level
- Demographic makeup of the lending area
- Mapping of lending patterns in the Banks’ defined market area
TCA guides you to A Better Way to comply with Fair Lending regulations and continue providing equal access to credit in your community.
Key deliverables include:
- Evaluating your Fair Lending practices at the Board level and across bank departments
- Providing sophisticated analysis to identify your lending performance, identifying any deficiencies, and making recommendations for preventing discriminatory practices
- Helping you to maintain the bank’s standing in the community.
- Assessing your Fair Lending risk level
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 […]
