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 Relief is Here for Many . . . Now What?
Last week the compliance and risk management worlds reacted with joy over the signing of Senate Bill S. 2155. For most bankers, the passing of this bill represented the most significant regulatory relief in decades. Of noted importance was the rollback of the expanded data collection rules for the Home Mortgage Disclosure Act (HMDA). However, […]
FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals
Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our […]
Mortgage Servicing Rules Part 2 of 3
Most of the provisions of the final 2016 Mortgage Servicing Rules took effect on October 19, 2017, with the remaining provisions effective April 19, 2018. In Part 1 of this series, we focused on the Definition of Delinquency, Requests for Information, Force‐Placed Insurance, Prompt Payment and Crediting, and the Small Servicer Determination. Part 2 of […]
New Rule for Using Closing Disclosure When Resetting Tolerances
On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is […]
FFIEC Joint Statement on Cyber Insurance
On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final […]
What is the Cloud Part 2: Risk Appetite Discussion
The goal of my last article was to eliminate the mystery of the “Cloud” by breaking it into easy‐to‐understand building blocks. A key takeaway is that the cloud is not a single operating option; it has many building blocks. The blocks or choices have a significant impact on your bank’s risk exposure. To make it […]
