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
HPML Appraisal & Regulation Z and Regulation M Exemption Amounts Hold Steady for 2021
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M, 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 have released the new index […]
SAFE Act MLO Registration Renewal Period Starts November 1
It’s that time again. The NMLS 2020 Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their NMLS […]
Three Hot CRA Concerns
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs, […]
SCRA Notice Changes
We are not sure when it occurred, but HUD slipped in two changes to the SCRA notice since it was last changed in March 2018. Both changes are in the final section within two bullet points. In the first bullet point, the website address for the Military Legal Assistance Office Locator was shortened, presumably to […]
TCA IS ON THE MOVE!
TCA has moved our corporate headquarters from Chicago to Oak Brook, Illinois. While we are sad to leave our home for the past 30 years, we are excited for the new opportunities our new headquarters will provide. Given its central location, our new office is easily accessible from downtown Chicago, the suburbs, the airports, and […]
Ready for HMDA 2021 Filing?
On August 21, 2020, the CFPB released the 2021 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides changing the references of “2020” to “2021,” the other changes are less cosmetic, such as updated descriptions and instructions for certain fields and revisions to certain edits. Also, we note they […]