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
Renewed Focus on Overdraft and “Junk” fees
One of the consequences of shrinking interest rates and interest margins is that financial institutions’ reliance on non-interest income has significantly increased over the last decade. The Consumer Financial Protection Bureau (CFPB) published an initiative on January 26, 2022 stating its intention to research the impact of fees on American consumers. The press release specifically […]
B Prepared for Compliance in Commercial Lending
It’s common for many lenders to believe that commercial lending is exempt from federal compliance regulations. However, this would be untrue – commercial loans are subject to the following compliance regulations: Regulation C/HMDA, Flood Disaster Protection Act, and Regulation B/ECOA. This article will focus on only one the regulations above – Regulation B. Under this […]
2022 Census Tracts Changes What it May Mean for Your Assessment Area
The 2020 Census data has been released by the US Census – and it may impact your Assessment Area for CRA and your Lending Area for Fair Lending. The Federal Financial Institutions Examination Council (FFIEC) which provides uniformity and consistency in the supervision of financial institutions, incorporates the US Census data in a format that […]
A Refresh on Regulation B’s Special Purpose Credit Program
On April 26, 2022, Wolters Kluwer conducted a webinar “Special Purpose Credit Programs: Everything You Always Wanted to Know”. The speakers included: Patrice Ficklin, Fair Lending Director of the Consumer Financial Protection Bureau Pamela Perry, Vice President, Single-Family Equitable Housing, Freddie Mac Kenneth Scott, Citibank Anand Raman, Skadden Arps The speakers discussed the credit needs […]
SCRA Notice Changes
HUD updated the SCRA notice of servicemember rights which is to be provided to all mortgage loans which are delinquent. The notice is required to be provided within 45 days from the date a missed payment was due. We reviewed the form and the only changes we saw were an update of the expiration date […]
Regulatory Updates – Second Quarter 2022
Below is a link to the Regulatory Updates as of the end of Q2. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here. As always, TCA is here to help with A Better Way to answer all […]
