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.
We were notified by a customer on September 27, 2019 that there are 72 POS debits totaling $1,373.01 from PlayStation on her account that she did not
authorize. Since Visa will only allow us to go back 120 days for disputes, how much of these transactions is the bank responsible to refund to the
I am reviewing a debit card dispute and it is one that we denied because after investigating, we found out the customer had signed up for this
service, but I am still a little concerned with the way the provisional credit was handled. The bank received the dispute (in writing) on 11/9/18.
The final letter was mailed on 11/21/18; however, no provisional credit was ever given. I was under the impression that if we received the dispute in
writing, we need to give provisional credit within 10 days. Are we in compliance?
When mailing statements, notices, etc. for a custodial account, would the mailing address be the address of the minor or the custodian? Can a mail "in
care of" be set up so that the mail goes to the custodian or does it have to be mailed to the minor?
A merchant refunded a customer after we closed our investigation. Are we out the money?
We were recently told that the way we process Reg E claims (and have been since before I was here and never had an audit issue besides wording of a letter) is backwards.
Here are the few scenarios that will tell me which is right. It's September 2019:
1. If a customer comes in and says they haven’t balanced their statement for 5 years and just realized that $14.99 has been being debited from their account by Amazon since March 2016. Can you tell me what amounts or for what time periods they are owed and for which months/years?
2. If the same scenario happened but the first charge was on April 10th of
this year? Can you tell me what they are owed and for which months?
3. Last, if the customer comes in and says that he is balancing his
statements for the past two years and found several different charges that are fraud:
a. A cable bill that debited for two months after he revoked authorization in 2018.
b. Amazon Prime debited monthly for 12 months from June 2018 to May 2019 and he never agreed to it.
c. GEICO debited his account $113.00 when he hadn’t authorized it to debit his account for that payment in August 2019.
If a customer places an order online, but never receives their merchandise, do we have to investigate?
Since MasterCard’s Zero Liability covers ATM withdrawals and PIN transactions. It is even worth investigating Reg E claims since we are always on the hook?
We have a member who is filing debit card fraud and claims that his card was not received in the mail. The card was activated and the caller used the
correct last four of his social security number to activate it. Is this enough to deny the disputes?
Since Reg E does not apply to businesses, do we have to investigate a fraudulent business debit card transaction?
Our processor says we don’t have chargeback rights since a purchase was made using MasterCard SecureCode. Can we deny the claim since the cardholder’s password was used?