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
HMDA Open-End Credit Threshold Maintained through 2021
On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020. In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline […]
Appraisal Threshold Increased to $400,000
Get ready to update those policies and procedures! On September 27, 2019, the OCC, FDIC and FRB, in concurrence with the CFPB, published a revision to the appraisal rules at 12 CFR 34, 225 and 323 increasing the threshold amount where a residential real estate transaction requires a state-licensed, certified appraiser from $250,000 to $400,000. […]
Ready for HDMA 2020?
Well, the CFPB is well on the way! On September 25, 2019, they released the 2020 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides timing and changing references of “2019” to “2020,” the changes appear to be items like updated descriptions and instructions for certain fields and revisions […]
Cannabis Bill Passes U.S. House
On the eve of National Compliance Officer Day (and ironically when TCA published a discussion on banking industrial hemp), the United States House of Representatives passes H.R.1595 Safe Banking Act of 2019 which, if signed into law, would protect financial institutions from examiner criticism for providing banking services to cannabis-related businesses. The bill provides for […]
National Compliance Officer Day
Today is National Compliance Officer Day, so TCA® wanted to share some recommendations from our compliance team with our fellow compliance professionals on potentially banking clients who may be engaged in activities relating to the cannabis industry. The challenge of providing banking services for industrial hemp and CBD Oil is that there are no current […]
CFPB Releases HMDA Public Data Tables
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2018. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can […]
