Fair & Responsible Banking
Treliant’s Fair & Responsible Banking team consists of former bankers and regulators.
Our highly experienced team is uniquely positioned to guide and partner on any fair and responsible banking, CRA, or HMDA challenge. We offer analytical, advisory, assessment, and assurance services. We can help you proactively strengthen fair lending, fair housing, Community Reinvestment Act (CRA), Home Mortgage Disclosure Act (HMDA), and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) programs; prepare for compliance examinations; and resolve regulatory concerns.
Redlining Reviews for Nationwide Lender
Treliant performed fair lending statistical analytics for a nationwide lender to identify target markets, peer groups, and potential redlining risk related to its Home Mortgage Disclosure Act Loan Application Register (HMDA-LAR) portfolio. We subsequently performed a market penetration review on the target markets, analyzing unique data sets (e.g., third-party channels and marketing data) to identify opportunities for increasing mortgage lending activities in majority-minority areas in each target market.
Compliance Management System (CMS) Builds and Evaluations for Regional Bank
Treliant conducted an independent review of a regional bank’s fair lending program to evaluate fair lending risk in its small business lending operations and its Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) compliance readiness, in preparation for potential supervision (upon reaching the $10 billion asset threshold) by the Consumer Financial Protection Bureau (CFPB).
Examination Readiness and Response for Community Bank
Treliant assisted a community bank in resolving administrative actions and supervisory criticisms of the bank’s credit markets, geographic lending patterns, fair lending audit program, and compliance audit procedures. The review results yielded observations and recommendations for written responses to the bank’s regulator as well as risk management strategies.
We know fair and responsible banking, regulatory expectations, and the supervision and enforcement environments.
Our subject matter experts have:
- Implemented or evaluated fair and responsible banking programs at a wide range of financial services companies, e.g., community banks, large banks, FinTech companies, mortgage companies)
- Performed independent regression analyses, redlining reviews, and model validation services, often in partnership with law firms, for all types of loan portfolios, e.g., mortgage, indirect auto, small business, credit cards, and other consumer loans and lines of credit
- Prepared compliance teams for fair lending and CRA examinations, assisted with written responses on regulatory matters, and implemented corrective actions
- Conducted fair lending comparative file reviews
Treliant has a proven track record of consulting in the following areas:
Examination Readiness and Response
- Exam Preparation
- Examination and Audit Response, including Issue Resolution, Action Plans, and Remediation
- Design, Follow-up, and Verification of Action Plan Effectiveness
- HMDA and CRA Data Integrity (“Data Scrubs”)
- Data Collection Process Improvement
Redlining Analytics and Assessment Area Reviews
- Development and Evaluation of Assessment Areas, Service Areas, Credit Markets, and Reasonably Expected Market Areas
- Lending Patterns for All Loan Types
- Loan Servicing Outcomes
- Deposit Patterns
- Branch Placement
- Marketing Coverage
- Statistical Analysis
- Objective Ratings
- Identifying and Evaluating Controls
- A Proven Formalized Methodology
- Fair Lending Risk Statements and Questionnaires
- Fair Housing Risk Statements and Questionnaires
- UDAAP Risk Statements and Questionnaires
- Risk Performance Outputs for Management and Regulatory Reporting
- Flexible Platform for Manual or Automated Integration with Governance, Risk, and Compliance (GRC) and Enterprise Risk Management (ERM) Systems
- Matched Pairs, Statistical Sampling, or Outliers
- Independent or as Corollary to Regression Analysis
- Second Reviews of Denied Applications for Credit or Loss Mitigation
- Exceptions and Overrides Monitoring
- Mortgages, Consumer Loans, Small Business Loans, or Commercial Loans
Community Reinvestment Act (CRA) Compliance
- CRA Program Assessments
- Assessment Area Evaluations
- Branch Network Reviews
- Geographic and Demographic Penetration Analyses
- Performance Context Development
- Data Validation and Data Integrity Reviews of HMDA Data, CRA Microdata, and
- Community Development Lending and Investments
Home Mortgage Disclosure Act (HMDA) Data Integrity and LAR Filing
- Data Integrity Review and Scrubs
- LAR Filing
Fair and Responsible Banking Training
- Development of an Ongoing Training Program for Fair Lending, UDAAP, Community Reinvestment, and Community Development
- Job-Specific Content Tailored to your Financial Services Company
Ready to Talk?
Treliant works closely with its clients to understand their needs and design an appropriate work plan and approach to each engagement. Learn more when you connect with our team.