Bio:
Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.
Mr. Crow has been, and continues to be, an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.
Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud.
See all Upcoming and On-Demand training presented by Brian.
Questions Answered
07/25/2021
I have a question about telephone transfers. The telephone transfers we perform are for the customer who calls the bank and requests the teller to withdraw from one account and transfer funds to another account. We currently have a custom form that a customer signs to perform ongoing telephone transfers and we keep this on file authorizing the bank to perform these transactions. We would like to discontinue using this form. Is this old form necessary and is it even a compliance requirement under Electronic Fund Transfer Act? We currently document on the transaction ticket "Telephone Transfer per Customer request". Any advice or information would be greatly appreciated.
07/25/2021
Can a customer initiate an ACH Return for unauthorized debit from a closed bank account?
07/25/2021
During a review of the account, we noticed several transactions to Cash App, to the same people from last December and one in January. These were NOT disputed. Should we inquire about these transactions? If so, could we start our calculation from the statement date (plus 60 days) from the statement with the first unauthorized transaction? Does it make a difference that the December, the May and June transactions were on different cards? (The customer has had multiple cards.)
07/25/2021
I have a commercial customer who had her signature forged on payroll checks in her January statement. Can these items be sent to the BOFD for collection now that we are in early May?
07/18/2021
A CTR filing is required for a customer for a certificate of deposit made using a $15,000 cash brought in. Would it fall under "negotiable instrument"? The customer also wanted a copy of her statements. She gave $2 cash for the fee, would this fall under "payment"? Need clarification since our auditor did not consider certificate of deposit purchased a negotiable instrument.
07/11/2021
Can anyone tell me what the retention period is for hold notices/funds availability forms?
I have checked with our state bank department and this form was not specifically addressed. If it is not uniformly required, how long do other banks keep these Reg CC notices, and what about cash advance receipts (Visa)?
06/20/2021
Is a bank required to send in counterfeit currency to the Secret Service or report and turn it into the local police department?
06/20/2021
I am working on a loan to a local municipality in Pennsylvania that was formed by court order in 1857. They have no record of the order at the Township and it pre-dates our state's records. Is there a method to properly ID old municipalities like this that will comply with OFAC requirements?
06/20/2021
I am working on a loan to a local municipality in Pennsylvania that was formed by court order in 1857. They have no record of the order at the Township and it pre-dates our state's records. Is there a method to properly ID old municipalities like this that will comply with OFAC requirements?
06/06/2021
What is the bank's responsibility when it comes to online banking fraud? We have a customer, his niece got ahold of his account number, signed him up for online banking, sent out P2P payments to herself and others, and now he's negative in his account. He did file a police report against her. Does this fall on the customer or the bank?
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