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 a customer who has been in Afghanistan for the past 5 years due to their being in the military. The customer has come back to the United States and has discovered unauthorized withdrawals which took place 5 years ago - about a month after they were deployed. Are we in compliance if we deny the claim, or we obligated to pay due to fact our customer was not receiving statements to Afghanistan. The account was charged off in 2007 and customer discovered this on her credit report.
When a customer reports an error or unauthorized card transaction on their account before it is actually posted (pending transaction) are we obligated under Reg E to begin the investigation process with regard to provisional credit within 10 days? We see that only about 40-50 percent of these pending claims actually post.
We have a difference in opinion amongst management in our Operations Department concerning Reg CC Holds and new accounts. The Reg states that if all account owners have "had, within 30 calendar days before the account is established another account at the depositary bank for at least 30 calendar days" the account will not be considered a new account. The problem is with the definition of "account" under Reg CC. Some read the Reg and think we should waive all new account holds for existing customers with any type of account (Checking, NOW, Savings, CDs, and IRA CDs). Some think that we should waive new account holds on existing customers who have transaction accounts (excluding CDs and IRA CDs). Which is correct? Also, let's say a customer has been with the bank for 2 years and has a checking account with a balance of $30K. He deposits a check into a new money market for $250K. Would we be non-compliant of the Reg if we placed a new account hold on the $250K deposit? Technically the money market account is not new because the customer has an existing account but the new account deposit is so much more than what the customer currently has. What if that $250K check comes back?
Are we required to give 2nd day availability on a Cashier's Check that is deposited into a New Account? Is the Exception Reason for New Account a valid reason on a bank's Cashier Check?
My bank took a check for deposit that was returned Altered Check within the 24 hour deadline. The question then arose, "What would our liability be?" Say the drawee bank did not return it timely. Their client has 30 days from the date of the statement showing its payment to notify them. The bank then has 30 days to submit a claim to my bank. Is my bank obligated to pay this money back?
If a person is added to an account as a convenience signer, is that account subject to a levy. (IE-Account owner is Sue Smith, conv. signer is John Doe. If the bank receives a levy on John Doe, are we required to levy that account even though he is not actually the owner?)
We had customers whose debit cards were compromised at locations they shopped. They were sent letters notifying them of the hack and they were advised to notify their bank and get a new card issued. Two weeks later, their cards were compromised, and they supplied copies of the notice only after their accounts were compromised. Can we charge them up to the $500.00 limit or amount of fraud for failure to notify us timely?
A customer opened a new transaction checking account on 8/17/11. On 9/2/11 the customer deposited a not on-us Official Check in the amount of $4000.00. Is the bank allowed to place an exception hold on this deposit using the New Account reason?
What are the rules/penalties for a UTMA account in Texas, when a custodian redeems funds from an account if the child is over 25?
Can a merchant charge a fee, or require a minimum transaction amount, when their customer chooses to pay with a credit/debit card?