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.
I was wanting to know if it is required to mail a monthly bank statement if there is no activity on the account? We have several customers who basically just use their account to cash checks and generally don't have any activity. Currently we mail the statement with no activity but I wasn't sure if it is required.
What do we do when a debit card transaction (debit or credit) is trying to post to a closed account? We understand that we must post the funds, but if the customer no longer has a relationship with the bank do we mail a check to them for credits? Can we send an adjustment or dispute?
Does a stop payment on an ACH item end after 6 months?
At what point would a CTR be filed for a Reg E dispute claim which states that over $10,000 in cash was deposited in the ATM? At the time a provisional credit is posted to the customer's account or at the time the Bank decides to make the provisional credit permanent, which could be 45 days? What business date is then used for the CTR, date of deposit in the ATM, provisional credit date, or permanency decision date?
We are needing to know what an expired W-8BEN means to the bank, is it a big deal? If so what should the time frame be to get a current W-8BEN from the customer and what should the consequence be if the bank does not receive one?
With the new Reg CC rules effective July 2018, how will a user be able to differentiate between an electronically created item (ECI) and a remotely created check (RCC)? Will there be an indicator on the file that identifies these items?
As to identification of a beneficial owner on a legal entity account, are we required to actually "verify" the information they give us, or will them giving us a copy of their Driver's License and telling us their Social Security number be sufficient? Some beneficial owners may not necessarily be in the bank when the account is opened, and therefore cannot provide permission for us to run their information through Chexsystems or another similar consumer database. I know we will collect a copy of the identification and keep this on file for the recordkeeping requirements and we will also perform an OFAC check, but are we required to verify this information? And if we are, how will we accomplish this without a signature from them?
We have a Visa POS Dispute from a customer as fraudulent card in possession, however it was through PayPal and verified by Visa. She stated she did not have a PayPal account. The dispute came back as no recourse since Verified by Visa was used. Is this sufficient to reverse provisional credit?
If a wife has POA for her husband can she add herself as authorized signer and add herself as the pay-on-death beneficiary?
We are changing our Certificate of Deposit from a single rate to a tiered rate. My question is, do we need to post all the various levels of each CD term on our lobby board?
For example, right now 12 month CD has a minimum deposit of $1,000 and the APR is 0.65 and the APY is 0.65. When we change, the 12 month CD will be $1,000 to $9,999, with the APR being 0.65 and the APY is 0.65, $10,000 to $24,999 , the APR is 0.70 and the APY is 0.70 and for $25,000 and above, the APR is 0.75 and the APY is 0.75.
Does the lobby board need to show that for each CD term?