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.
During a recent compliance forum I understood the consultant to say that the 7 day notice of withdrawal language needed to be a part of the TISA disclosure – even if it is part of the terms and conditions disclosure. It is not at our bank.
I spoke with a bank manager that has a background in compliance but has been out of the deposit compliance loop for several years. He says that as long as it was in our T&C then we should be fine.
I can’t get what the consultant said out of my head – can you help? Is there a citation that addresses this in Reg DD or Reg D? Maybe I misunderstood?
For the new Reg D regulation changes for COVID-19 in which withdrawal limits are waived, does the bank have to provide a notice of change within 30 days of the change or not? Is the notification requirement waived if the change is temporary and/or the change is permanent?
Are banks able to accept checks for deposit or cashing that have no payee written on the payee line? What is the risk behind accepting these checks?
We have seen customers commit fraud by using remote deposit capture to deposit the same check at multiple banks, by using the same image of the check front but different check backs in order to use multiple restrictive endorsements. Under Reg CC or the UCC, what is the best way to argue against another bank that their claim is legitimate and ours isn’t? Both banks have an image with their restrictive endorsement, and theoretically the captures could have been made within a short amount of time. How can we defend ourselves from being left holding the bag?
How should we report a victim of Identity Theft on SAR Form? Should our customer`s information (victim) be added to Part 1 Subject Information? We have no information on predator.
Can the bank legally close or freeze an account that is suspected of money laundering and hold the funds in a general ledger account pending investigation?
Is it acceptable to not credit a customer for an error on a deposit (when performing proof of deposit) when the error is under $10.00, retaining that amount in income for the bank. I got an opinion that this was acceptable and was called "dominium's amount." If this practice is legal, should we have it disclosed in our Deposit Agreement?
I have a few questions regarding Reg CC:
1. For accounts less than a year old, and a check is over $500, we place it on a 2-day hold, is that allowable under the Reg?
2. For accounts open more than a year and checks more than $3k but less than $5k, we place it on a 2 day hold, is that allowable under the Reg?
3. Does Reg CC apply to A2A deposits or mobile deposits?
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.