For years now, mobile deposits have carried some risk due to the outdated rules of Regulation CC. The final rule creates a new Remote Deposit Capture (RDC) Indemnity in Section 229.34(f) to address the allocation of liability when a depositary institution, such as a credit union, accepts check deposits through “remote deposit capture.” Mobile remote deposit capture, and specifically, the ability for a fraudster or forgetful person to deposit a check by taking a picture using their smart phone, and then depositing the paper copy at a different financial institution or check-cashing business, was not taken into consideration by these two pieces of regulation. Remote Deposit Capture: A Primer To remain competitive, financial institutions continually look for ways to cut costs, attract new customers, and boost revenues. Remote deposit capture emerged as an unintended consequence of the Check Clearing for the 21st Century Act and is growing in popularity. These locations may be the financial institution’s branches, ATMs, domestic and foreign Over the years, NAFCU‘s Compliance team has been asked if Regulation CC‘s funds availability schedule applies to checks deposited through remote deposit capture (RDC). Remote deposit capture (RDC) technology helps to streamline and improve the efficiency of one area … Remote Deposit Capture (RDC), the digital processing of paper checks and monetary instruments at remote locations for deposit and clearing through the check (image) or ACH networks, has expanded rapidly in recent years and is being used at financial institutions and at customer locations. The process of … A new bundle of Reg CC changes on July 1, 2018 will, among other things, affect FIs’ responsibility for checks accepted by remote deposit capture (RDC).. RDC has become an essential banking innovation, by putting the ability to deposit checks in the hands of any business or consumer. Fundamental to the efficient and effective deployment of banking technology is the understanding of the regulatory implications and the development and integration of a compliance program as part of the design and implementation process. In the past, liability (or the indemnity) for a check that was deposited twice - once by mobile deposit and once by depositing the paper check - would fall on the bank that accepted the mobile deposit. New warranty and indemnity rights, liabilities and obligations to Regulation CC went into effect July 1, 2018. Here are the highlights of a few of the Federal Reserve’s amendments to Reg CC: Shifting the Loss for Remote Deposit Capture Although remote deposit capture is convenient for customers, the service can be a nightmare for a bank. These amendments will take effect on July 1, 2018, and they aim to recognize current collection practices. Risk Management of Remote Deposit Capture Background and Purpose Remote Deposit Capture (RDC), a deposit transaction delivery system, allows a financial institution to receive digital information from deposit documents captured at remote locations.

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