Bio:
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.
Questions Answered
05/14/2012
I am currently going through a review of ATM/REG E procedures with our internal Compliance dept. They are requesting that we apply interest to disputed REG E amounts because of the Deposit Compliance Program. I have not heard of having to apply interest to disputed REG E transactions. Should we be applying interest on transactions that are disputed under REG E?
05/14/2012
What are the purposes of custodial accounts and what different types are there?
05/14/2012
I have tried to contact both Mastercard and Visa and I still don't know. Can I charge a fee for processing a non-customer's cash advance from their credit card?
05/14/2012
If a Final Credit is given to a customer for an Unauthorized Debit Card Transaction, but later the merchant also reverses the debit (or gives a credit), can the bank send another letter to the customer explaining since they got the credit twice, we are taking our Final Credit Back?
05/07/2012
We have a customer that is highly disabled and unable to take care of herself without outside help. She needed cash and gave her ATM card to this person along with the PIN so that she could get cash. The helper withdrew unauthorized additional funds. Our customer filed dispute with us. My questions are we released from giving her funds back since she gave the PIN? Also, can we make her file a police report and press charges against the person or we'll withhold her funds?
05/07/2012
We wanted to place a CBC hold on a large check. We did not want to hold the funds for 7 days as would be for an exception hold. Is there an amount limit for case by case holds?
05/07/2012
Our Bank is considering using a "Request to Reinstate VISA Debit card and Account Overdraft Agreement" for customers continually overdrafting their account with their Debit Card. What are some of the compliance issues we may face?
04/30/2012
Customer disputes several charges saying card was stolen. She notified us on 1/18. We gave provisional credit and filed with Mastercard who in turn reimbursed us. Now Mastercard took back the money from us since there are signed receipts of the transactions which happened on 1/17. Since they are saying the transactions were legitimate can we do the same and get our money back from the customer? What if we believe it is her signature based on documents we have on file?
04/30/2012
What form replaces PDF 4881 (December 2001) when requesting to redeem Savings Bonds for a deceased individual?
04/23/2012
We have a client that did business with a non-bank company to handle their "accounts". Our client does "campaign" accounts for rebate programs for pharmacy drugs. They have closed many of the accounts with this old company but they still have rebate checks older than 6 months hitting their old account. The checks are returned, but this company is charging them for each return item fee. Is this legal? Does the UCC guidelines help them in any way with the 6 month "stale date" definition OR can this non-financial company continue to charge them every time an old rebate checks tries to hit an old account?
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