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
OCC Updated Addresses for Equal Housing, CRA and Adverse Actions
If you are not regulated by the OCC, then you can skip to the end of this Special Release. If you are regulated by the OCC, then you need to know the OCC issued Bulletin 2021-35 on August 5, 2021 updating addresses used for the Equal Housing Lender lobby posters, CRA lobby notices for the […]
CFPB Releases HMDA Public Data Tables
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File. […]
Covid-19 and Compliance Engagements – Update
Throughout this pandemic, TCA Compliance has looked to the Centers for Disease Control and Prevention (CDC) for guidance on how best to manage the effects of COVID-19 on our business. As many states, including Illinois, are entering into Phase 5 of their COVID strategies (i.e. are re-opening), we have continued to look to the CDC […]
A New Federal Holiday. What Now?
On June 17, 2021, the U.S. got its first new National Holiday in 38 years. June 19th has been designated as “Juneteenth National Independence Day.” Our last new National Holiday, Martin Luther King, Jr. Day, the third Monday in January, was instituted in 1983. So, what’s different about these holidays and why does it affect […]
OCC’s CRA June 2020 Final Rule – Maybe
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors […]
When the Tide is Against You
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]