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
11/05/2023
Most recently we have received requests from business customers asking to keep their accounts open after identifying fraud. This fraud is related to checks that have been intercepted, washed and negotiated. Due to convenience of keeping existing account open, our customers are requesting that we do not require them to close the compromised account.
We read a FinCEN FAQ regrarding keeping accounts opened after receiving "keep open" requests from law enforcement. We are wondering if other financial institutions follow procedures to "keep open" these compromised accounts based on a request from law enforcement and use that same procedure on customer requests, assuming the procedure helps reduce risks of any loss? What do you see as the pros and cons of keeping the account open when it is a customer request?
10/15/2023
Since Reg E does not apply to businesses, do we have to investigate a fraudulent business debit card transaction?
10/15/2023
Since Visa’s Zero Liability covers ATM withdrawals and PIN transactions. It is even worth investigating Reg E claims since we are always on the hook?
10/15/2023
Can we require a copy of a customer’s receipt if they are disputing the amount of a charge?
10/08/2023
Can we require a copy of a customer’s receipt if they are disputing the amount of a charge?
10/08/2023
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?
10/01/2023
If a customer places an order online, but never receives their merchandise, do we have to investigate?
09/24/2023
Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?
09/17/2023
A customer purchased KETO Bites and states the cost was $39.99. She immediately received an invoice along with charges to her account for the amounts of $59.99 and $239.99, not for the $39.99. Does provisional credit need to be given for those amounts and is the dispute considered fraud?
09/03/2023
If we have a revocable living trust, and the Grantor and Trustee are different, would we CIP both the Trustee and
Grantor, or just the Trustee?
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