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
Lots of Regulation Z Updates
Based on the 0.1% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2020, the Consumer Financial Protection Bureau (CFPB) released a number of new triggering thresholds which go into effect on January 1, 2021. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. […]
New Hemp-related Business Guidance
On June 29, 2020, FinCEN published FIN-2020-G001 providing guidance for obtaining due diligence information for hemp-related businesses. The BSA industry has wrestled with cannabis and its derivative rules since FinCEN’s initial 2014 guidance for banking marijuana-related businesses. Between 2014 and 2018, hemp was equated with marijuana since both are derived from the same plant. However, […]
Adverse Action Notice Requirements For Loans and Deposits
When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses […]
LIBOR – CFPB Proposes Amendments to Reg Z to Facilitate Transition
We have all heard that the LIBOR index may no longer be available after 2021 and over the past year TCA has received many questions regarding the transition from the LIBOR. How do we prepare? What is the replacement index? Is there advance notice required? On June 2, 2020, the CFPB released three items related […]
Limited Open-End Credit eSign Exemption Due to COVID-19
The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally […]
Covid-19 and Compliance Engagements
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. Now that stay-at-home orders are being lifted and businesses are reopening, we’ve again relied on the CDC in developing a strategy to protect the health […]
