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 non-customer presents an on us check for $11,000, the check is cashed and the non-customer receives the entire $11,000. When completing the CTR would you check box 32 Negotiable Instrument(s) Cashed, box 34 Deposit(s)/Withdrawal(s), and box 35 Account Number(s) Affected (if any) or just box 32 and 35? Would this transaction be considered a "Withdrawal" (box 34)?
Who assumes the loss for paper checks created by a vendor who claims to have the customer's verbal authorization to debit his account, and the customer claims he did not authorize the transaction?
Tax Levy-- Can the bank charge their fee of say $100.00 when they receive the levy and then place the lockout on the account for what is remaining in the account? Or could we take the account negative for the fee after 21 days?
Can a revocable trust be a POD on an estate account?
Can we cash checks the are a few years old if they do not say "void after 90 days" on them?
Debit card dispute: what does Reg E say on this? Customer stayed at a motel and booked through PriceLine. They were booked in smoking and asked for nonsmoking which they received. They left around 5:30 AM, received a call from the manager saying the comforter had a burn place on it and they charged them $200.00 for this. She said they noticed this when they checked in but did not say anything. She wants to dispute the $200.00 charge since they will NOT refund back to her debit card. My question is do we have to do this dispute or do they need to settle this with the motel?
I have a customer that willingly gave her card information (not the physical card) to her daughter for legal expenses. The customer told her daughter she could pay her legal fees and nothing else. But the daughter also used the card to pay for her boyfriend's release from jail. A total of 3 charges (2 of which were the daughter's legal exp) occur over a span of about 2 weeks. The 1st charge is the daughter's, the 2nd is bail, and the 3rd is daughter's - chronologically speaking. Where does the bank stand on liability? Are we obligated to reimburse the customer for the bail payment?
Assume a customer used their debit card to set up a recurring payment (for example) for a gym. They have okayed the payment for the last several months and now the customer says this is not correct. What steps do we need to take such as under Reg E? Can we return a POS for a Stop Payment?
My understanding of Regulation E is we can require a member to provide written notification of unauthorized debit card use within 10 business days in order to receive provisional credit. In the meantime, we would begin our investigation. In order for us attempt charge-backs, we need to have an unauthorized debit card use statement signed by the member. If the member fails to sign this form and our investigation is then over, can we take the provisional credit back providing we follow the guidelines at 205.11(d)?
I have a customer who is disputing a monthly telephone charge of $27.06 (Virgin Mobile). This same charge has been coming out of his account for 18 months, totaling $487.08. He advised me of this error on 5/30/12. My question is: What part of this amount is our bank liable for?