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.
We have an item that was returned with the incorrect return reason code. It was returned as a forgery but should have been an endorsement. The item is payable to a business and endorsed by an individual. The payee claims to have not received the item in the mail. We received the item back as a late return claim. Can we return the item again for the correct return reason? What is the time frame for an improper endorsement?
We received notice from our core processor that we will be charged for a debit card transaction that is not our customer, the card is not on us and the merchant is not a customer. We are disputing this with our core processor but they say we will be charged for the transaction. Why can this transaction not be returned when it wasn't on us? I have no idea how it reached our core processor and was processed for our bank.
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.
Can a POS transaction be returned for insufficient funds and charged an overdraft fee if our bank does not offer overdraft protection? Would there
be a benefit for a customer to "Opt In" if we continue to not offer overdraft protection?
It has been my understanding that a bank has up to a year to return items in the event the item is altered or the endorsement forged. I have another
bank stating that the midnight deadline applies. Could you please provide clarification. I am located in Florida.
We were notified by a customer on September 27, 2019 that there are 72 POS debits totaling $1,373.01 from PlayStation on her account that she did not
authorize. Since Visa will only allow us to go back 120 days for disputes, how much of these transactions is the bank responsible to refund to the
I am reviewing a debit card dispute and it is one that we denied because after investigating, we found out the customer had signed up for this
service, but I am still a little concerned with the way the provisional credit was handled. The bank received the dispute (in writing) on 11/9/18.
The final letter was mailed on 11/21/18; however, no provisional credit was ever given. I was under the impression that if we received the dispute in
writing, we need to give provisional credit within 10 days. Are we in compliance?
When mailing statements, notices, etc. for a custodial account, would the mailing address be the address of the minor or the custodian? Can a mail "in
care of" be set up so that the mail goes to the custodian or does it have to be mailed to the minor?
A merchant refunded a customer after we closed our investigation. Are we out the money?
We were recently told that the way we process Reg E claims (and have been since before I was here and never had an audit issue besides wording of a letter) is backwards.
Here are the few scenarios that will tell me which is right. It's September 2019:
1. If a customer comes in and says they haven’t balanced their statement for 5 years and just realized that $14.99 has been being debited from their account by Amazon since March 2016. Can you tell me what amounts or for what time periods they are owed and for which months/years?
2. If the same scenario happened but the first charge was on April 10th of
this year? Can you tell me what they are owed and for which months?
3. Last, if the customer comes in and says that he is balancing his
statements for the past two years and found several different charges that are fraud:
a. A cable bill that debited for two months after he revoked authorization in 2018.
b. Amazon Prime debited monthly for 12 months from June 2018 to May 2019 and he never agreed to it.
c. GEICO debited his account $113.00 when he hadn’t authorized it to debit his account for that payment in August 2019.