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
CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices
The Consumer Financial Protection Bureau (CFPB) announced on March 16, 2022, the added scrutiny of illegal discriminatory practices within its examination procedures for Unfair, Deceptive, Abusive Acts and Practices (UDAAP). The CFPB considers that illegal discrimination practices based on services or products can cause consumer harm; therefore, UDAAP should be included with the other Fair […]
What Does Your Institution Need to Know About Evolving Russian Sanctions?
As the war in Ukraine escalates, the United States, by Executive Order from the President, has issued increasingly restrictive economic sanctions against Russia. As the volatility increases, the challenges facing U.S. financial institutions to avoid processing prohibited transactions also increases. As the effective date for several sanctions approaches, individuals and businesses may attempt to send […]
Regulatory Updates – 2021
It’s challenging for every Compliance professional to stay on top of the small and big changes to existing and new regulatory requirements. As you partner in compliance, we are introducing a new feature to our Regulatory Compliance Manager (RCM) Service – Quarterly Regulatory Updates. This is A Better Way for you to keep track of […]
Deposit Insurance Changes for Trusts and Mortgage Servicing Accounts
On January 21, 2022 the FDIC notified insured Institutions of simplification for the calculation of Deposit Insurance for Trust Accounts and Mortgage Servicing Accounts which will be effective April 1, 2024 (so, plenty of time to ease into the change). If you don’t want to read the 62-page regulation, you can always read on, or […]
FFIEC Releases 2020 CRA Public Data Tables
On December 21, 2021, 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 […]
HMDA and HPML Thresholds Bumped Up for 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 Index for Urban Wage […]
