Specialties
Model Governance
Data Integrity
Model Output and Performance
Helping you meet regulators’ demands for independent AMS model reviews
We bring the people and know-how to conduct rigorous, risk-based AMS model validations to assess how well your model governance, data integrity, and parameter thresholds adhere to regulatory guidance.
Conducting an AMS model validation is both an art and a science.
Hundreds of banks and credit unions view us as trusted artists and scientists and count on us to bring insightful regulatory intelligence during AMS model validations.
With real-world experience as former bankers, we understand the effect of increased regulatory pressure on your team. Relying on plug-and-play settings, for example, is a path to frustration, and we know how it feels to be overwhelmed by alerts and struggle to discern what warnings to heed or ignore.
Members of our team have done everything from examining data integrity and its quality and conducting “above the line” and “below the line” testing to assessing a model’s design and how well it’s tailored to your risk profile.
We also bring a solid track record in understanding the quirks of various AMS solutions in the marketplace and performing system validations on them.
Our assessments consider both IT and BSA perspectives, and we focus on three areas:
- Model governance
- Data integrity
- Model output and performance
Throughout each engagement, we communicate with you to keep you informed on our progress and findings. At the conclusion, our exit meeting and written report document our scope, methodology, findings, and recommendations.
Once our AMS Validation is complete, you can be confident that your model is sound and meet examiners’ escalating expectations.
TCA gives you A Better Way to gauge whether your AMS model meets its objectives and protects you from money-laundering risks.
Key Deliverables Include:
- Testing administrative controls, data import, and data integrity.
- Reviewing system parameters to be sure they’re functioning correctly and identifying suspicious activity.
- Ensuring that your model has been calibrated to your bank's risk profile.
- Analyzing exams, reviews, and monitoring reports to trace the resolution of issues requiring corrective action.
- Providing exceptional service that respects your time.
AMS Insights
Updates to Updates to the FDIC Official Signage Rule and Q&A
The FDIC delayed the implementation date for the updates to 12 CFR 328.4 (Signs for automated teller machines and like devices) and 328.5 (Signs for digital deposit-taking channels) which were originally to go into effect as of January 1, 2025, and postponed to May 1, 2025. TCA – A Better Way!
New HMDA Filing Login Requirements
If you are a HMDA filer, CFPB has made the filing process more secure or more complicated depending on your viewpoint. According to this quick reference guide, effective January 1, 2025 a Login.gov login, which includes multifactor authentication (MFA), will be required to file your institution’s 2024 HMDA data. Users will no longer have the […]
Regulatory Updates – Fourth Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q4 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
Time to Make New Year’s AML/CFT Resolutions
While many of us will be making personal resolutions for the New Year for personal self-improvement goals, AML/CFT Officers should consider a few resolutions that are geared towards their AML/CFT Programs. TCA – A Better Way!
HMDA and HPML Thresholds Bumped Up for 2025
On December 27, 2024 the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and on December 23, 2024 the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. TCA – A Better Way!
CRA Asset-size Thresholds Announced for 2025
The annual CRA asset-size thresholds for covered financial institutions were announced by the FDIC and Federal Reserve on December 19, 2024 and by the OCC on December 23, 2024 applicable for 2025. TCA – A Better Way!