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.
A business customer deposits $9,750.00 in cash to their checking account and then gives the teller $300.00 in bills to get coin. Is a CTR needed and if so do you report $10,050.00 as cash in and nothing in the cash out column or $300.00 in the cash out column?
When the bank processes a merchant dispute on behalf of the customer and it does not fall under Reg E, are we under the same time frame as Reg E as far as 10 day provisional and finalizing the dispute within 45 days?
What if we sent a letter to them after the 45 days and then the merchant rejects the claim with valid information, can we go back and debit the customer?
We want to offer a savings account for students. We are thinking of offering a higher rate on the first $1,000 deposited and then our normal rate on balances over that. This will be effective for one year and then the rate goes to our regular savings rate at that time. If we put up a banner on our building and state the higher rate, do we need to also state an APY on the banner? And what balance would we use to disclose the APY? The APY for $1,500 and $2,500 are considerably different.
Please tell me a correct way to open benefit account.
Can I refuse a stop payment order if the customer cannot pay for the service?
What is the maximum penalty that a bank can charge on a certificate of deposit?
What is the difference between a service charge and a maintenance fee?
Can you now have an authorized signer on a trust account? The trustee is the owner of the trust and the successor trustee is her husband. She is wanting to put her daughter as an authorized signer just to sign checks in the case she gets sick and can't. After her husband (who is also aging), her 2 sons are the trustees.
As it relates to ODP programs, have there been any recent updates or proposals related to debit card authorizations approved on a positive balance, but which are then presented against insufficient funds because customer has used the funds and the bank is not allowed to assess OD/NSF fees on the debit card item? (This assumes the customer has opted-in for Reg E inclusion of debit card transactions.) I've heard this may be considered a UDAAP problem but haven't found any publications on the subject.
Recently we have been receiving Breach of Warranty Claims for fictitious checks and/or forged maker signature checks drawn on the Bank's submitting the claims.
My understanding is that under the UCC the paying bank has until its midnight deadline to return a check for these reasons. We initially denied the claims, but have now received demand letters stating that are in breach of warranty provisions.
Along with these claims, banks are providing hold harmless agreements stating that their customer has filed formal complaints with law enforcement. From what I can ascertain they are attempting to use the warranty to claim that the creation of a fake check is an "alteration". We don't belong to a clearing house that allows warranty claims on fraudulent checks.
Any insight you can provide is most greatly appreciated.