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
Updates to the FDIC Official Signage Rule and Q&A
The Board of the FDIC met on October 17, 2024, and delayed the implementation date for the updates to 12 CFR 328 Subpart A (FDIC Official Signs and Advertisement of Membership) which were to go into effect on January 1, 2025. The new mandatory compliance date is May 1, 2025. TCA – A Better Way!
HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2025
On October 4, 2024, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections […]
Regulatory Updates – Third Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q3 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
Back to School: Ready for Regulators’ Pop Quizzes?
With the summer winding down, the kids will be heading back to school and facing tests and the dreaded pop quizzes. But they are not the only ones. Compliance pros also must be ready for regulators’ tough questions. If your regulator were to give you a pop quiz, would you be ready? See if you […]
FDIC Issues Questions and Answers on New Signage Rule
On July 16, 2024, the FDIC published a Questions and Answers Related to the FDIC’s Part 328 Final Rule page on their website. The rule is effective as of April 1, 2024 with a mandatory compliance date of January 1, 2025. The FDIC expects to continually update the Q&A as needed. Like most Q&As, some […]
Regulatory Updates – Second Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q2 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!