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
07/18/2021
A CTR filing is required for a customer for a certificate of deposit made using a $15,000 cash brought in. Would it fall under "negotiable instrument"? The customer also wanted a copy of her statements. She gave $2 cash for the fee, would this fall under "payment"? Need clarification since our auditor did not consider certificate of deposit purchased a negotiable instrument.
07/11/2021
Can anyone tell me what the retention period is for hold notices/funds availability forms?
I have checked with our state bank department and this form was not specifically addressed. If it is not uniformly required, how long do other banks keep these Reg CC notices, and what about cash advance receipts (Visa)?
06/20/2021
Is a bank required to send in counterfeit currency to the Secret Service or report and turn it into the local police department?
06/20/2021
I am working on a loan to a local municipality in Pennsylvania that was formed by court order in 1857. They have no record of the order at the Township and it pre-dates our state's records. Is there a method to properly ID old municipalities like this that will comply with OFAC requirements?
06/20/2021
I am working on a loan to a local municipality in Pennsylvania that was formed by court order in 1857. They have no record of the order at the Township and it pre-dates our state's records. Is there a method to properly ID old municipalities like this that will comply with OFAC requirements?
06/06/2021
What is the bank's responsibility when it comes to online banking fraud? We have a customer, his niece got ahold of his account number, signed him up for online banking, sent out P2P payments to herself and others, and now he's negative in his account. He did file a police report against her. Does this fall on the customer or the bank?
06/06/2021
I have a reportable CTR to file. It was created during banking hours. I found out that our client did a POS and got cash back. The POS transaction happened after banking hours. Do we need to add the cash back amount to the reportable CTR?
03/14/2021
Our customer authorized a transfer but was scammed into completing it. The customer received a message from someone posing as an Apple support person. She called in response to the message she received and the person posing as the support rep instructed her to set up a Google Pay account with her debit card attached, which she did. The scammer then orchestrated the transfer of funds via Google Pay and our customer is now disputing these charges. What are our responsibilities regarding this dispute since the charges were technically authorized?
02/07/2021
Is it a requirement to gather Beneficial Ownership information on loan guarantors?
01/17/2021
If a large not-on-us check was split between a new savings account and an existing checking account, (not the ideal scenario) would you split the availability of the $5,525.00 on the 2nd business day between the two accounts and make the balance available on the 9th business day?
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