RDC

Great question...as my bank does not have daily limits. I'm currently auditing RD and would like to make a recommendation to start doing this....I'd be very interested in some feedback as well.

We set daily deposit limits and daily item limits per account used by our customer.

Along the same lines as our credit limits for ACH Origination.

previous bank set limits along the lines of ACH as well, which is sort of silly as if they come into the branch to deposit there are no limits. If you do your homework on the customer, you shouldn't need to set limits.

Our "homework" on our customer was equivalent to that of assessing credit limits for ACH Origination. At least if they come into the branch to make the deposit, there is a review of the items deposited by the teller that offers some degree of assurance. Regulators like the idea of setting limits as part of the risk assessment, no matter how silly it seams.

Skyline - it is very silly, especially since any "review" by a teller is cursory at best, and if anyone thinks it provides a degree of assurance it is a false sense of security. Of course, you should also have someone who is reviewing your RDC deposits, so I wonder why that sense of assurance doesn't cross over there. I had an OCC Examiner tell me I needed to set limits for RDC and I said I would set the same limits I have for customers coming into the branch to deposit. He said that was an excellent idea, what was that limit. I said there is none. It took him about 10 seconds and he started to tell me how it was an issue not to set limits, and I asked him to show me language that specifically required limits be set. That ended that discussion.

Good going!