Financial institutions currently face enormous risk with regard to both CRA and fair lending compliance. Although these risks currently are significant, they will likely increase considerably with new public data reporting requirements that are on the horizon. These new requirements will provide a great deal of information to regulatory and enforcement agencies to analyze bank CRA and fair lending performance as well as making this data publicly available. These changes will allow analyses and the ability for conclusions to be drawn from information that is now typically only available through the regulatory review process. It seems clear that these changes alone will elevate CRA and fair lending risk for financial institutions.
Being successful in CRA and fair lending compliance requires a proactive approach and analysis of key areas or “pressure points.” Institutions that consistently avoid regulatory pitfalls have managed processes in place that involve analysis of the key data elements, coupled with making necessary changes and adjustments to enhance their performance. Without managed processes, an institution is simply gambling with their compliance and exposing themselves to a great deal of unnecessary risks. Premier Insights provides an array of services in this regard and can provide comprehensive services or supplement existing bank efforts.