Bio:
A BSA/AML master, Brian brings 20+ years of banking experience to his current role as EVP at Thomas Compliance Associates, inc.
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 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.
Questions Answered
06/09/2024
Does state law take precedence over Reg E when it comes to length of time a consumer has to report unauthorized debit card activity? If State law is more favorable to the consumer, then we have to follow state law. right? I am trying to find out if a consumer can report unauthorized debit card activity after, say, 2 or 3 years in Massachusetts.
05/05/2024
Should you log a cash advance to the BSA log after the cash advance was used to purchase a Cashiers Check? No money was exchanged.
04/21/2024
Under Reg CC, how are deposits made by debit card treated? (These might be a deposit at an ATM or a merchant refund on a debit card burchase, as examples.) Can we hold these for three days even for existing customers?
04/21/2024
We received a "Notice of Freeze" from the Florida Department of Revenue on one of our customers. Is there a set procedure for handling such notices from a state authority or do they differ by bank and or the state the bank or the customer is in? Would this procedure be the same for an action from a governmental entity as from a private action like an unpaid debt?
04/07/2024
Can a bank offering cash advance services through Mastercard choose to stop offering that service?
03/24/2024
We have a customer that is falling for the "publishers clearing house, you won a million dollars" scam and is wanting to send these people $15,000. We have tried to explain to her that it is not real, and she just gets agitated. We talked her out of getting a cashier's check but now the customer has written the scammer a personal check for $15,000. Do we as a bank have a right to place stop payment on this? Can or should we get the police involved? Is there anything to stop this lady from being taken advantage of?
03/24/2024
Is a DBA (Doing Business As) certificate a requirement for CIP purposes?
In Arkansas, it is required that a DBA certificate is on file with the county clerk for businesses.
03/24/2024
How do banks handle loan solicitation checks at their branches? Do all banks accept these types of checks, or are we even required to? If they are accepted, when do they give the customer availability or could this type of check be sent for collections?
I thought collections was only for foreign checks.
03/03/2024
Can a check that was returned as FROZEN ACCOUNT be redeposited?
03/03/2024
We continue to have issues collecting customers current physical addresses when opening new accounts. Our frontline thinks they find loopholes in our policy, deviating from the intent of the policy, and they create larger problems.
Is it permissible to have a policy or procedure in place for changing the address on a new account for a new customer within 30 days of the date opened? Say if a customer opens an account on the 10th and then comes in on 21st to change their address, do other banks have a policy to collect a proof of address at this time since it is a new account?
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