Question: In January 2009, the Federal Financial Institutions Examination Council (FFIEC) issued guidance for examiners, financial institutions and technology service providers for Remote Deposit Capture (RDC) systems. Simply stated, RDC systems allow financial institutions to process deposits online without the use of paper checks or other documentation; however, this increases the risk to customers and their assets. How can your organization protect its customers from RDC-related risk?
Answer:
Identify the legal, compliance, reputational and operational risks associated with the bank's RDC system.
Educate customers about RDC documentation, operations and procedures for their direct deposit and online banking needs.
Be sure that your staff and customers understand Check 21 and its implications for the banking industry.
Clearly define roles, responsibilities and liabilities of all parties in the RDC process in contracts and customer agreements to minimize exposure to legal and compliance risks.
Establish a training program to be sure that all staff understand the bank's RDC system as well as any current regulations concerning it.
Ensure that the bank's RDC system is compatible with its business strategies.
Assess and monitor risk to security and confidentiality on a frequent basis.
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