Automated Monitoring System (AMS) Model Validation

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

mortgage loan disclosure

HMDA and HPML Thresholds Bumped Up for 2023

By | January 10, 2023

On December 28, 2022, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price […]

regulations block as piece of a puzzle

New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections

By | January 6, 2023

Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase […]

heloc

CFPB Releases Revision to Regulation Z HELOC Booklet

By | December 28, 2022

The Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, “What You Should Know about Home Equity Lines of Credit,” also known as the HELOC booklet, required by the Truth in Lending Act/Regulation Z (1026.40(e)). The CFPB states this version of the HELOC booklet (dated 8/22) is updated “to align with […]

community reinvestment act

FFIEC Releases 2021 CRA Public Data Tables

By | December 22, 2022

On December 15, 2022, the FFIEC released the public disclosures for CRA data submitted for calendar year 2020. Note: If your institution does not report CRA small business, small farm or community development lending data, then this Special Release would not apply to you. Even if your institution is not a CRA reporter, a review […]

home mortgage application

HMDA Reporting Threshold Changes Due to Court Ruling

By | December 20, 2022

On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. Effective July 1, 2020 the number of closed-end loans originated to be considered a “financial institution” was increased from 25 to 100 for each of the two preceding years for both depository and non-depository institutions. On September 23, 2022, […]

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2023

By | October 19, 2022

On October 13, 2022 the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators […]

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

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