Many bank compliance departments require the treasury team to do annual onsite audits of their RDC customers to verify that they are still conducting business from the registered location with the bank. Slideshare uses cookies to improve functionality and performance, and to provide you with relevant advertising. RemoteDepositCapture.com Contracts should clearly detail the authority of the bank to mandate specific internal controls, conduct audits, or terminate the RDC relationship. Obtaining expected account activity from the RDC customer, such as the anticipated RDC transaction volume, dollar volume, and type (e.g., payroll checks, third-party checks, or traveler’s checks), comparing it to actual activity, and resolving significant deviations. See what else we’ve invented and built for the past 60 years, How we build our scanners to be the most reliable in the business. See our User Agreement and Privacy Policy. Another major national bank took a $50 million penalty and $110 million in forfeitures from the OCC, FinCEN and DOJ, also triggered in part by foreign RDC transactions. … The LAR (Legal Amount Recognition) field contains the amount of the check in written form. Red flags may include the velocity of funds in the account or, in the case of ATMs, the number of debit cards associated with the account. Quick stat 19.4 billion. They should ensure that RDC is compatible with the institution's business strategies and understand the return on investment and management's ability to manage the risks inherent in RDC. Counterfeit items may be similarly difficult to detect. And I am talking about MONEY LAUNDERING risks - not fraud risks (i.e. & What used to be controlled pilots are products available immediately that focus on new sectors. He has written numerous articles on banking technology and the payments system, has authored or co-authored six books and recently published "Capturing Your Customer! 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, http://www.ffiec.gov/ffiecinfobase/index.html, http://www.ffiec.gov/bsa_aml_infobase/default.htm, Freedom of Information Act (FOIA) Service Center. Financial institutions should develop and implement risk measuring and monitoring systems for effective oversight of RDC activities. See NACHA publication "Third-Party Senders & the ACH Network: An Implementation Guide.". Duplicate presentment of checks and images at the institution or another depository institution represents both a business process and a fraud risk. Separation of duties or other compensating controls at both the institution and the customer location can mitigate the risk of one person having responsibility for end-to-end RDC processing. Institutions should ensure that customers using RDC have implemented operational and risk monitoring processes appropriate to their choice of technology. Finally, BSA/AML is not the only regulatory implication financial institutions need to address. 9 See USA PATRIOT Act §312, 31 CFR 103.176. A division of Digital Check since 1999, STImaging makes digital microfilm and microfiche reading devices for individual viewing.

The training should include documentation that addresses issues such as routine operations and procedures, duplicate presentment, and problem resolution. Specific contract provisions for consideration include: Senior management should ensure the financial institution's ability to recover and resume RDC operations to meet customer service requirements when an unexpected disruption occurs.

More micro businesses are expected to use RDC in coming years, … To reduce the risk of items being processed more than once, deposit items can be endorsed, franked, or otherwise noted as already processed. Most retail banks need this to migrate branch-based transactions to digital channels and free up the branch channel to move into a more current sales and service platform. Inadequate separation of duties at a customer location can afford an individual end-to-end access to the RDC process and the ability to alter logical and physical information without detection. For example, credit cards, deposit accounts, mortgage loans, and funds transfers can all be initiated online, without face-to-face contact. 14 The financial institution should consider including in its contracts and agreements provisions establishing cut-off times and specifying how and when the customer will know the institution has accepted the deposit.