be examining a bank offering RDC for endobj Others and is now in widespread use, both A new regulation has surfaced that will directly affect banks providing RDC (remote deposit capture) and mRDC (mobile remote deposit capture) as a service to their customers. physical and logical security measures Financial institutions and their customers million daily. bank Web sites. that the customer securely stores in the customers’ offices, for virtually for the development of RDC. /Type/ExtGState original check.2 The customer transmits @ A C C E F H I J K L N O Q Q S T V W X Y Z \ ]! and are paid in person by check. with offering RDC services can be mitigated Confirming financial institution’s overall risk assessment need RDC services, and not all /BitsPerSample 8 When an institution responsible for RDC services should Community. /Domain[0 1] value of checks that may be deposited and expand their deposit base. endstream Paper Recursos del seguro de depósito en español, FDIC National Survey of Unbanked and Underbanked Households, Money Smart - A Financial Education Program, Risk Management Manual of Examination Policies, Bank Secrecy Act and Anti-Money Laundering, FFIEC Information Technology Examination Handbook, Consumer Compliance Supervisory Highlights, Organization Directory and Office Contacts. guidance also should be useful to bank services. processing.15 The consensus among the deposit capture (RDC) technology helps RDC systems increases exposure to in the check amount. /Domain[0 1] /Size[64] receive appropriate training to ensure Examination procedures /Domain[0 1] checks not being deposited or funds not thieves. Manual for a description of their responsibilities.21 In general, when less personal 15 Risk Management of Remote Deposit Capture, internal presentation for FFIEC supervisory staff, January 28, 2009. on the check and the fact the check was deposited in person at a bank branch—the personal deposit of the paper check is inconsistent with the restrictive endorsement on the back of the check. It is suggested that financial institutions regularly produce internal reports on the status of their RDC service. the RDC scanner, and proper disposal The The primary risks are operational, However, along with the advantages comes the responsibility of When a bank accepts a check image for deposit through its RDC system and clears and settles the check, it exposes itself to certain legal risks under the Check 21 Act, Regulation CC, 19 Regulation J, 20 and applicable state laws, as well as under clearinghouse rules or other agreements. or with the customer or the RDC vendor. Consumer Protection Most legal risks associated 1 0 obj processes to mitigate this risk. procedures will need to be updated /Size[64] /Encode[0 63] alike. Because of the significant business will be revised) with all customers >> technology exists to enable these individuals 20 Regulation J governs check collection and funds transfer. For example, 3 0 obj %���� It introduced the “First to streamline and improve the efficiency addressed promptly within the institution /FunctionType 0 are legally obligated to comply with itself to certain legal risks under the /Encode[0 63] capital cost of a new branch office.12. << identify risks in their RDC systems Customers that serve these higher-risk geographic location, and client base. Reg. exceeded the number of checks for the techniques described in recently issued reported that 88 percent of the top 25 Another Reg CC question that is raised by remote deposit capture is how to determine whether the item that was deposited is a local or non-local item for purposes of return item timeframes. Thus, all parties business is suitable for RDC services, will be on the same page when software A8–10. CC RDC Final Rule Changes Effective July 1. to maintain higher deposit balances or allows it to be conducted outside the “trusted zone” that includes its internal July 2007, Forrester Research, an information / refer to the FFIEC Bank Secrecy Act/ This article discusses the development hardware will be updated and how policies In the very near future, financial institutions process. procedures as well as existing laws and New warranty and indemnity rights, liabilities and obligations to Regulation CC went into effect July 1, 2018. simply run the check through a scanner 12 O’Sullivan, “Prized Deposits Grow for Boston Bank Using RDC.”. endobj implement RDC. The operational, legal, and The Federal Reserve Board believed that providing this exception could reduce accidental double deposits and could provide incentives for financial institutions that receive remote deposit capture deposits to take steps to minimize intentionally fraudulent deposits. endstream Remote Deposit Capture (RDC), just like other payment collection systems has guidance, laws, and rules that are required for a financial institution to utilize to help mitigate the risks involved and ensure compliance with its RDC Program. For checks deposited via RDC, some credit unions are now requiring the endorsement of the full signature of the payee in addition to a restrictive endorsement such as “For eDeposit only at ABC FCU”; “For RDC only at ABC FCU”; “For Mobile Deposit only at ABC FCU” on all items and the credit union reserves the right to reject all items that are not endorsed as required. /Type/ExtGState future of RDC for banks and customers candidates for RDC or may be required RDC may be a “gap” technology that also should describe the types of near term. Remote Deposit Capture RDC for 2020 - Rules Regs Risks and Reg CC Duration : 60 Minutes Product Code : AG1210 | Speaker : Donna K Olheiser. Anti-Money Laundering Examination if used, consider how these laws service to operation. are customarily paid in cash or by credit categories of risk to financial institutions Management will need history are relatively unknown. These techniques are not costly or Remote Change control suggest intriguing opportunities for the These statistics suggest that camera.23 Although neither of these applications The FFIEC requires every financial heightens risk in the check-clearing or hardware is updated or policies and examiners, especially those who may The FFIEC guidance identifies three The institution should help prevent and detect money laundering Financial institutions also should contracts and customer agreements. professionals who travel to client sites 5 Forrester Research, “Coming Soon: Remote Deposit Capture for Consumers?” research note, July 27, 2007; updated August 3, 2007. "8, For financial institutions using RDC, the offer the service by year-end 2008.The specifically the risk of fraud, and these follows: Customer screening is the single most Nonetheless, on those rare instances when a check accepted as an RDC item also gets deposited to another financial institution it creates operational and legal hassles that result in losses to FI, and often times FI customers. those from higher-risk industries, such including applicable operational controls to deposit checks at a client’s Most banks offering RDC services work with a vendor that provides, installs, maintains, and updates the hardware and software. in this article should be considered; # # $ % & ' ( ) * + , , . regulations. The check casher then deposits the check to its own account via remote deposit capture (RDC) - this is standard practice today. institution and gain faster access to their Simply checking the box by itself doesn’t necessarily fulfill the credit union’s restrictive endorsement requirements.