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 had a business deposit customer who had a check to deposit that was made payable to a homeowner and his company. His company completed repairs to the home. We did not accept the check for deposit because the homeowner was not present. Is this correct?
We had a customer book a two day hotel reservation through a popular hotel booking website with their VISA debit card. When the customer arrived at the hotel they were not satisfied and did not believe the hotel was as advertised on the website. The customer called the hotel booking website and they offered to refund her the money and find her another hotel. The customer said they would stay in the hotel for one night and accept the refund for the second night. The customer only stayed in the hotel for one night but was charged for the two nights. When she called the hotel booking website back they claimed that they had no record of the incident and would not refund the money. My question is do we have chargeback rights on this item or is there no error because the customer initially authorized that amount when they made the reservation?
If a person uses a counter check and writes it out for "cash" in the Pay to the Order of line and signs the bottom of the check, Does that person have to sign the back also?
A husband and wife each have a living trust. Husband and wife are trustees of both trusts. Can they have a joint account with their respective trust as joint owners?
Scenario: John Doe is incarcerated in September. While in jail, John Doe's girlfriend takes his MasterCard debit card and makes multiple unauthorized ATM transactions at the beginning of October. John Doe stays in jail until the end of January of the next year. When released he looks at his online bank statement and realizes his card has been used for ATM charges back in October. Is the bank held liable to return funds to the customer if the charges are almost 90 days old?
We are changing our debit cards from Visa to MasterCard. Do we need to send a new EFT disclosure?
Is "for deposit only" a legal endorsement and does it require a signature for depositing?
We have proprietary ATMs that accept deposits and process withdrawals. We are clear regarding both Reg E notices (on or at machine and screen/paper with specific fee). We are not clear on Reg CC. We know we need to include at each ATM the notice "funds deposited in the ATM may not be available for immediate withdrawal" as required by Reg CC 229.18(c). Do we ALSO need to post our Funds Availability Policy at each ATM location in addition to the notice (229.18c)?
This is in regards to Reg E. Say there is a member who went to an ATM and tried to deposit a check but was unsuccessful. Without cancelling the transaction or pushing "no further transactions" and receiving the card back, the member walks away from the ATM. During this time there had been another person waiting in line to use the ATM. Well as soon as the member left, the other person came up to use the ATM but noticed that the previous person hadn't cancelled the transaction and the ATM still waiting for further instructions on what to do next. The person withdrew $300.00 and then tried to withdraw more but was unsuccessful. Is this a Reg E claim? Obviously it is theft but I don't think it is Reg E due to it not being an error that the credit union made but the member made. I know that the Reg protects the member from being negligent but its not like the member lost the card with the PIN written on the card. The member never finished the transaction and walked away with the card still in the ATM waiting for further instructions.
Does a hold notice have to be given to the customer before they leave the bank?