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
06/09/2019
Our bank has several MSB check cashing customers. On occasion, an MSB customer will inadvertently cash an altered check, which eventually is deposited to their account at our bank. When our bank receives an affidavit of alteration from the paying bank, is it permissible to debit the MSB customer's account for the claim amount since they are the ones that "cashed" the check, or would our bank be responsible for paying the alteration claim?
06/09/2019
Our customer says "I canceled my account with the merchant" but does not provide any documents showing the account was canceled or says "my bill was suppose to be $23.00 but I was charged $37.00 and does not provide a receipt. Can the bank, since there is no evidence the error was invalid, decline the dispute?
05/19/2019
Can a POA add beneficiaries on an account?
05/19/2019
I'm hoping you can confirm my understanding that a paying institution is liable under Reg CC 229.38(a) for failing provide notice of nonpayment for a check in the amount of $5,000 or more under 229.13(c)? The measure of damages under 229.38 is the loss incurred up to the amount of the check, less the amount of the loss that would have been incurred had the paying institution exercised ordinary care. Can you provide an example of a liability calculation in which the paying institution's notice of nonpayment is late?
How does the bank of first deposit pursue a claim against the paying institution for failing to provide proper notice by the deadline? I assume this would be on a "without entry" basis by sending a demand letter to the paying institution.
05/19/2019
I'm hoping you can confirm my understanding that a paying institution is liable under Reg CC 229.38(a) for failing provide notice of nonpayment for a check in the amount of $5,000 or more under 229.13(c)? The measure of damages under 229.38 is the loss incurred up to the amount of the check, less the amount of the loss that would have been incurred had the paying institution exercised ordinary care. Can you provide an example of a liability calculation in which the paying institution's notice of nonpayment is late?
How does the bank of first deposit pursue a claim against the paying institution for failing to provide proper notice by the deadline? I assume this would be on a "without entry" basis by sending a demand letter to the paying institution.
05/12/2019
I have been trying to find what the requirements are for giving bonuses to open a new account. There are advertisements everywhere of cash offerings, freebies, or giveaways. We’re still stuck on the value of offer cannot exceed $10, however we see TV ads offering $300 to open an account.
What compliance issues do we need to address if our offerings go beyond $10? As an example, April is Teach your Children to save month. Marketing has come up with a campaign that if you come by and get a piggy bank and bring it back full of coin with your child and use it to open an account, the bank will also deposit $10 into that new account, or it could be an existing account.
05/05/2019
Should the owner of a sole proprietor business account cash checks made payable to him personally using the business account?
05/05/2019
If only 1 person is 100% of the corporation can they name a POD on the checking account?
04/21/2019
We would like to create an easier way for our consumers to sign up for E-Statements. What are the requirements, compliance wise for this? Currently, our customers need to log into their online banking, view a PDF disclosure that generates a "code", and customer then has to type in code and agree to terms and conditions. Compliance wise- can consumers just sign the disclosure/consent in person at lobby?
03/24/2019
If a business customer has a privately owned ATM in their business, are they considered an MSB?
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