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.
You can contract Brian at b_crow@tcaregs.com.
07/25/2011
I have a customer who was making monthly payments for a service of some kind. The money was being deducted from his account via his Debit Card number. In April, the company went under and has closed. He states he has not received all that he has paid for. My question is: Should the bank be on the hook for this dispute or is this something we can deny and have him resolve on his own?
07/18/2011
If we offer an account without check writing, does a "wet" signature need to be obtained during account opening or can that step be eliminated?
07/11/2011
In most cases, when an EFT error (ACH) is reported to us, the investigation is initiated immediately and completed within 10 days. Our bank requires written confirmation for all EFT errors that are reported. We realize that without written confirmation, it does not delay the initiation or completion of the investigation. However, what are our requirements for crediting if the customer does not give us written confirmation within 10 days? Do we have to follow the provisional credit rules? Or do we just let the reported error “hang” until we get that written confirmation?
07/11/2011
Joint account; A husband withdraws $100.00 from account 123456789 at the ATM. The co-owner withdraws $10,000.00 from account 123456789 at the branch. Is a CTR required?
07/04/2011
Is there anything in Reg E / Opt In that prevents it from being offered to bank employees?
07/04/2011
Scenario: John Doe has his and his wife's VISA-branded debit cards stolen (he has possession of both of them). The PINs are written on or in his wallet with the cards. He notifies us within a day of the loss. The Card thief uses the cards, and between both cards, spends approximately $2,700. Several transactions are at an ATM. Others are POS transaction, and we're determining now if they're PIN or Signature-based. What will the bank's liability be on all these transactions, taking the customer's negligence into account?
07/04/2011
Our financial institution issues the VISA check card to our customers. We have had fraud issues that VISA denies us charge back rights on. They are protecting the merchants and the ones committing fraud but what about the cardholders and card issuers? Shouldn't VISA reimburse us for this loss? How can a FI get restitution for the money they lose when protecting their customers against fraud?
06/27/2011
We have a Reg E claim where the client is claiming seven transactions (the total amount disputed $5800.00). The provisional credit was issued on May 9th, 2011. On May 23rd, 2011, the merchant issued a credit directly to the client's account for two of the transactions disputed (five out of seven transactions still continuing under investigation). The amount credited $3700.00 is more than a half of the total amount of the claim. At this moment the credit is duplicate for these two trans. as per Reg E the final date for the investigation should be on July 22, 2011. Can we partially reverse the provisional credit issue (for the amount of merchant issued a credit prior to reach the final date of the investigation)?
06/27/2011
What responsibilities do we have as a bank whenever we find out that a check, that has been processed through our customer's account, is a forged item? Do we have the responsibility to return the item? Also, do we have the responsibility to then view all checks in our institution over a certain dollar amount comparing the signatures on the signature card to the endorsement(s)?
06/27/2011
A bank guarantees a business customer's endorsement for depositing a check. Are they verifying just the customer or the fact that they are an authorized signer for the business?