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
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 […]
HMDA 2018 File Format Verification Tool Now Available
Hot on the heels of the release of the HMDA data tables for 2017, the CFPB/BCFP has released its tool for validity checking the correctness of your Institution’s HMDA file for the calendar year 2018 data being submitted in 2019. You can find this tool at https://ffiec.cfpb.gov/tools/file‐format‐verification. The tool does exactly what it says: verifies […]
FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals
The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges […]
CFPB Releases HMDA Public Data Table
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017. 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 […]
