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.
Most of our customers are depositing checks remotely using a check scanner. We spot check deposits over a certain amount and have noticed occasionally some are made payable to multiple payees and they are not endorsed properly. We normally put a Reg CC hold on the deposit because most of the time the check is returned. We had one instance where the check was not returned and now the bank that issued the check is asking us for the funds back (6 months later) because of missing endorsements. We can't prevent the customer from depositing the check (unless we take the machine away), but what options do we have to get the other bank to return it, sooner than the 7 days?
What is the time-frame for POS transactions to hit customer's accounts if the FI has been notified of a problem with a posting file? Ex. POS Trans was in August and FI was informed by processor that there was a problem in October.
Per Reg E (and even MasterCard policies), what should our process be for debit card transaction disputes where the customer claims the transaction was unauthorized but it gets charged back to us with proof (invoice, order, etc) of authorization? Am I allowed to charge it back to the member? Am I allowed to delay giving provisional credit for any amount of time? Can I (as the FI) call the merchant to verify shipment of goods, etc?
Is there any type of hold (beyond 2 days) a bank can use when our concern is what if the check comes back and the customer has spent the funds, we would have no way to retrieve any of the funds other than legal action. Would it be wrong to select other and note questioning if the funds will be paid?
If we have a customer depositing $13,000 in cash to his business account and then getting a cashier's check for $11,000 made payable to a petroleum company, do we have to file a cash monetary form? Since he deposited the cash to his account, we already filed a CTR but the account was debited for the selling of cashiers check.
We have an account where someone has been forging checks and cashing them. What is the liability of the bank? Is there a time frame where the customer is just out of luck?
Debit card fraud claims: we currently require the member to complete a CUNA affidavit, cardholder dispute forms and provide a police report. Does this practice now cease as we know it? This is in regards to Reg E.
A local business issues their payroll checks and tells their employees if they cash them before 2:00 pm they will be terminated. Can they put restrictions on checks once they issue them? We think not and would like to advise the business accordingly.
I have a business whose Visa card was duplicated and a charge completed using a signature. Do I have to give them their money?
Does Reg E only pertain to transactions where a PIN was used? If we're a Visa issuer and they require a signed letter from the customer to process a chargeback, can we make that a condition of the denial should the customer fail to return a signed letter to us?