Duplicate Manual Business Checks, Blank Computer Checks on Top
In an effort to maintain this flexibility, the Reg CC amendments will allow financial institutions to continue to vary these new warranties by agreement (and other Subpart C provisions of Reg CC as they apply to “electronic checks” and “electronic returned checks”) based on the notion that institutions are in the best position to address and limit these perceived risks and to determine their risk tolerance. Home > Banking > Reg CC Goes “Paperless”: New Amendments Address Electronic Checks, Remote Deposit Capture, and Other Modern Banking Trends.
That change was effective 7/1/2018. New Indemnity for Electronically Created Items When mobile-deposited …
BankersOnline.com - For bankers. With the new regulations in place, financial institutions accepting mobile deposits now may have protection if they use a “restrictive endorsement.” In other words, if the financial institution accepting a mobile deposit requires an endorsement that prevents duplicate deposits, then they are less likely to have an indemnity claim filed against them by a different financial institution that accepted the duplicate paper check. Our goal is to help our clients stay up-to-date and successfully navigate the legal and regulatory challenges that may impact their business.
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Institutions might also consider discussing these issues with their third-party vendors providing remote deposit capture software to investigate whether the software can scan for proper restrictive indorsements. IRS Address Stamps
Have mobile deposits become subject to Regulation CC yet?. Take note that the regulatory language in Reg CC with respect to “non-local” checks is no longer relevant, and this old language will likely be fixed in the Federal Reserve’s next set of amendments. From bankers. For example, when a person uses remote deposit capture, he or she retains the original paper check, which he or she could attempt to cash again. Customer Communication is Key. Nowadays, all checks are “local” checks and must be made available to the customer by the second business day, unless of course an exception otherwise applies under Reg CC. As you can guess, an “electronically created item” can sometimes be difficult to distinguish from electronic images of paper checks. All Rights Reserved.
From training, policies, forms, and publications, to office products and occasional gifts, it’s available here: BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between. You've been inactive for a while. In June 2017, the Federal Reserve issued final amendments to Reg CC to get with the times, and the CFPB is expected to do the same shortly. Seasonal Stamps*New*
This leaves financial institutions with a decision to make on whether or not to change the endorsement requirements for any mobile check deposits.