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 Reporting Threshold Changes Due to Court Ruling
On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. Effective July 1, 2020 the number of closed-end loans originated to be considered a “financial institution” was increased from 25 to 100 for each of the two preceding years for both depository and non-depository institutions. On September 23, 2022, […]
HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2023
On October 13, 2022 the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators […]
FinCEN Issues Final Rule for Beneficial Ownership Reporting
On September 29, 2022, FinCEN issued a final rule for Beneficial Ownership Reporting to support law enforcement efforts. The rule establishes timeframes for legal entities to report beneficial ownership information FinCEN as required by the Corporate Transparency Act (CTA). According to the publication, FinCEN will have rulemakings to: Establish rules for who may access the […]
SCRA Notice Changes
HUD updated the SCRA notice of servicemember rights which is to be provided to all mortgage loans which are delinquent. The notice is required to be provided within 45 days from the date a missed payment was due. We reviewed the form and the only changes we saw were an update of the expiration date […]
A New Federal Holiday. What Now? Redux.
So, if this article looks familiar, that’s because we sent out a similar version last year when there was so much confusion with the timing of the signing of the law, but the information is still the same. (The dates have been updated, as applicable.) On June 17, 2021 the US got its first national […]
What Does Your Institution Need to Know About Evolving Russian Sanctions?
As the war in Ukraine escalates, the United States, by Executive Order from the President, has issued increasingly restrictive economic sanctions against Russia. As the volatility increases, the challenges facing U.S. financial institutions to avoid processing prohibited transactions also increases. As the effective date for several sanctions approaches, individuals and businesses may attempt to send […]
