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
TRID is all grown up – now what? TRID Exams Get Tougher
Happy Birthday, TRID! It’s hard to believe but the TILA/RESPA Integrated Disclosure Rule is three years old this October! Remember when it was a cute little Reg? No? I must confess, neither do I! From the onset of compliance in October 2015 to the publication of the final rule on July 7, 2017, TRID remains […]
SAFE Act MLO Registration Renewal Period Starts November 1 Finding Your MLO’s Registration Can be Tricky
The NMLS 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 will be able to complete their annual attestation that the company’s record is up to date, pay their NMLS processing […]
Quality Assurance Monitoring for BSA/AML Compliance Programs
When your institution is examined for compliance with any law or regulation, the measure of your efforts will be based on your ability to self-identify and self-correct any deficiencies. Ongoing monitoring of key processes helps to ensure that any errors or warning flags are identified early. Monitoring is a required element of a compliance management […]
FinCEN Finalizes Beneficial Ownership Relief for Certain Accounts
he exceptive relief for CD renewals, loan renewals and modifications, and safe deposit box renewals has been made permanent. The industry has challenged FinCEN for some time with the operational challenges of obtaining beneficial ownership certifications for these auto‐renewing products. FinCEN finalized this exceptive relief by making it permanent on September 7, 2018 in FIN‐2018‐R003. […]
CFPB Provides Guidance on Handling HMDA Changes
As we all well know, S.2155 provided some anticipated regulatory relief covering many areas. One of the relief items was HMDA relief, which TCA covered in a previous special release. As a quick refresher, the Act provides that an institution does not need to report data with respect to closed‐end mortgage loans if it originated […]
2019 Thresholds under Regulation Z’s CARD Act, HOEPA and QM Sections
Based on the Consumer Price Index in effect on June 1, 2018, which increased 2.5%, the Consumer Financial Protection Bureau (CFPB) released a number of new threshold amounts which go into effect on January 1, 2019. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged in […]
