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
Turning Downtime Into Uptime: Using Regulatory Lulls to Fortify Compliance
The Critical Role of Compliance Management System Risk Assessment We are all familiar with the emphasis placed on meaningful risk assessments throughout our industry. Among the many risk assessments that should be created for banks, the Compliance Management Systems Risk Assessment (CMSRA) is perhaps the most important. The importance of a thorough Risk Assessment cannot […]
FinCEN Updates Compliance Date for New Type of Special Measure
This is an update of our June 27,. 2025 article with updated dates. TCA – A Better Way!
FinCEN Issues New Type of Special Measure
As part of a supplemental appropriations bill passed in September 2024, Congress enacted the FEND Off Fentanyl Act. Section 2313(a) granted the U.S. Treasury the authority to impose special measures against financial institutions suspected of funneling illegal proceeds derived from the illegal manufacture, transportation, and sale of fentanyl. TCA – A Better Way!
Dodd Frank Section 1071 Small Business Data Collection Rule Postponed
On June 18, 2025, the CFPB published an interim final rule effective on July 18, 2025, postponing the effective date of Regulation B implementation of the Section 1071 Small Business Data Collection Rule. The summary states: In light of court orders in ongoing litigation, the Consumer Financial Protection Bureau (CFPB or Bureau) is amending Regulation […]
SCRA Notice Changes
Sometime in April 2025, 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 the missed payment was due. We reviewed the form and the only changes we saw were an update […]
OCC Consolidates Offices Changing CRA Addresses and Confirming ECOA and Fair Housing Poster Addresses
If your regulator is the FDIC, FRB or NCUA, you can stop reading here unless you wish to broaden your knowledge. On April 8, 2025, the OCC issued Bulletin 2025-6 “Community Reinvestment Act, Fair Housing Act, and Equal Credit Opportunity Act: OCC Contact Information for Certain Notices and Posters”. The Bulletin rescinded an earlier bulletin (2021-35) […]
