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
09/03/2023
A customer filed a number of POS transactions originating from Cash App and during our investigation we found out that the charges were linked to a relative of the customer (whom she's previously had issues with). Our customer claims they never authorized this person to use/access the debit card. The documentation stated a physical item was sent to the address that matches that of our customer, but the name linked to the transactions does not match our customer's name. Can we deny this claim since information links back to her address but not her name?
08/27/2023
We have a customer that placed a stop payment on a check. When the check cleared the check number was keyed incorrectly by the depository bank. Due to that happening the stop payment was not a direct hit, and it appeared on our Suspect List. The person checking off that list saw that the check number was different so they allowed the check to pay from the customer's account. Is our bank liable to pay the customer back for the check or does any liability lie on the depository bank?
05/14/2023
We have a customer who doesn't like the way we manage our safe deposit box entries. We use individual single-use entry tickets and the customer was used to their old bank using a card with running entries for the box. Their complaint is a piece of paper could be lost or an employee bribed to give it to someone who wants to enter the box illegally. We follow all the best practices. We would like to know the best way to handle the customer's concern short of changing the process for over 30 branches. Any suggestions?
03/26/2023
I would appreciate direction on where to find in the regulation(s) the requirement for counterfeit checks to be returned within a 24 hour period of payment. We have a client that has had a counterfeit check clear their account and needs proof that it must be returned the next day or it is considered a late return.
03/12/2023
I attended a great training webinar presented by BOL Guru Brian Crow on Mastercard vs Reg E rules. During the presentation he mentioned three Mastercard chargeback forms the bank could use in lieu of a signed cardholder document. Our operations department located two of the three. My question is, to inquire about the document form number for the "Expedited Fraud Dispute Form".
03/05/2023
A customer passes and an estate account is opened at another institution by the appointed executor of the deceased. We receive the death certificate and letter of instruction from the executor to disburse the funds to the estate at the other bank. Are any CIP forms needed for the executor or anyone else on our end?
02/26/2023
Can a check payable to an LLC be endorsed over to a corporation?
We have a customer that is wanting us to accept checks made payable to his LLC and allow him to deposit them into his corporation account.
02/19/2023
Regarding the Annual Error Resolution notice required by Reg E, for online statements can this resolution just be added to the website or does it have to be actually sent to each customer with their online statement?
01/01/2023
VISA and Mastercard rules both have "non-discrimination" clauses in their operating rules (for cash advances) that state if a maximum amount is established, it must be applied uniformly to customers and non-customers. I am searching the VISA Operating Rules but can't locate any specific language for uniformity of cash advances for customers vs. non-customers. Can someone tell me the exact VISA rule number and where I can find the exact clause (online) in the VISA Operating Rules?
12/11/2022
When advertising time deposit rates with a bump rate feature, what all is required?
Also how do you disclose a rate ceiling, as a rate or APY?
Pages
