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
CFPB Funding Mechanism Determined Valid
The Supreme Court released their decision in the Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd. case, which was brought to challenge the funding of the CFPB as inconsistent with the Appropriations Clause. The challengers argued that this funding mechanism violated the appropriations clause, which provides that “no money shall be […]
Regulation CC Updates Coming in 2025
When Regulation CC was updated back in 2019, one of the changes attached the dollar amounts to be made available to adjust every five years based on changes to the Consumer Price Index (CPI-W) similar to annual changes in Regulations M and Z, rounded to the nearest $25. Well, that far-off five-year timeframe has arrived. […]
Your Dream AML/CFT Home Starts with Good Bones
Build A Solid Foundation That Will Help You Detect and Combat Financial Crimes Prospective homebuyers want properties with “good bones,” whether buying new construction loaded with smart technology or a 200-year-old historic farmhouse that needs tender loving care. Good bones assure buyers that a property is structurally sound, provides a safe environment, and will be […]
HOEPA VS HPML (High-Cost and Higher Priced Mortgage Loan)
The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth-in-Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. Higher Priced Mortgage Loans (HPML) were implemented as part of the Mortgage Disclosure Improvement Act in 2009 […]
Tips for a Successful Offsite Review
The saying goes that the only constant is change, which is true. In this post-pandemic environment, TCA continues to complete most engagements remotely. Technology advancements have made the process easier, but offsite engagements create different challenges. Please take a moment to review some tips for an efficient, effective TCA remote review. Ensuring a Successful Remote […]
Mitigate Risk: Understand Your Lending Patterns
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan […]
