Bringing you a visual representation of your lending activity to help you uncover potentially discriminatory lending patterns.
We help you manage your CRA and Fair Lending risk by mapping your loan activity, identifying areas of gaps and related risk, and determining your loan penetration within underserved and minority communities in your market area.
Subtle changes in demographics and minority populations within your market area may go unnoticed, especially if your bank has expanded into new regions.
Failing to analyze and understand such changes, not understanding residents’ credit needs, and offering loan products unsuitable for the population can open you to risks.
You don’t want to be that bank and suffer reputational and financial harm because of a knowledge gap. Not understanding your banks’ lending patterns within your market area and inadequate marketing and outreach efforts could inadvertently lead to discriminatory lending practices.
We bring you the tools and talent to allow you to visualize your loan activity and show how you can adjust it accordingly.
Using mapping software, we provide a visual picture of your lending patterns and demonstrate neighborhoods or communities that may have been excluded or have limited lending activity.
By incorporating your lending data — loan applications, originations, and denials — we uncover your bank’s lending trends and gaps and pinpoint unseen biases.
After our analysis, you have a complete picture of your lending area and patterns, insight into whether your lending practices are sufficient, and strategies to improve credit access.
TCA gives you A Better Way to map your loan activity and accurately plan how to address your community’s credit needs.
Key deliverables include:
- Providing maps to allow you to make more intelligent and strategic lending decisions
- Helping you identify and proactively respond to population shifts in your market areas
- Identifying areas where residents face unequal access to credit
- Guiding you in enhancing your lending outreach and effectively meeting the credit needs of underserved communities and people from low-to-moderate income and minority backgrounds
Additional Fair Lending Topics
Is there any new fair lending risk that a financial institution should make sure is included in the Fair Lending Risk Assessment?
Answer: Yes. A new CFPB initiative has been developed known as PAVE – Property Appraisal and Valuation Equity. It is an Interagency Task Force to address inequity in home appraisals. Examiners will be looking to see how financial institutions ensure there is no appraisal bias in minority neighborhoods or minority homes by monitoring the financial […]
Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms?
Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected […]
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 […]
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