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
Important CTR Update – Compliance Date Moves From February 1, 2020 to September 1, 2020
TCA’s January 21, 2020 “CTR 101 Webinar” highlighted one key change to the FinCEN CTR report – the evolving expectations on how to complete Part I Item 2. The original October 1, 2019 Notice published required a February 1, 2020 compliance date. The January 17, 2020 Notice extends the compliance date for files to September […]
CRA Thresholds Announced for 2020
The annual CRA asset-size thresholds for covered financial institutions were announced on December 30, 2019 applicable for 2020. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 1.62% increase in the CPI, the […]
HMDA and HPML Thresholds Bumped Up for 2020
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 due to the annual percentage increase in the Consumer Price Index for Urban Wage […]
FinCEN Issues Guidance on Providing Financial Services to Hemp-Related Businesses
FinCEN and the regulators kicked off the holiday season by providing the industry with some clarification on the BSA implications of banking hemp-related businesses. In the News Release and Guidance, FinCEN said: “Because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a Suspicious […]
Regulation Z and Regulation M Dollar Thresholds for 2020
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new […]
SAFE Act MLO Registration Renewal Period Starts November 1 Check Current Registrant’s Names
It’s that time again. The NMLS 2019 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 […]