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Remote Deposit Capture - Exposure Limits
Question: Does a bank have to set "exposure limits" for a Remote Deposit Capture customer? We do not set limits at the teller line.
Answer: All of the federal and state regulators have been slow in publishing regulations and guidelines for Remote Deposit Capture, including the necessity to set exposure limits. However, if you consider the rationale behind the FFIEC and NACHA guidelines for exposure-it is required because of risk. Every bank is required by GLBA to conduct an annual bankwide review of risk factors and describe the controls that are in place to eliminate, or mitigate, risk.
Having a Remote Deposit Capture system means that tellers and bookkeepers do not have an opportunity to review the items before they are posted and in an environment where there are hundreds, and potentially thousands, of these customers-the possibility of fraud is almost certain. Like ACH Debit customers, reviewing them before they gain access to the system, establishing exposure limits and reviewing their financial position annually seems like a regulatory certainty.
T. Houston Technology Group provides a full range of Remote Deposit Capture legal and regulatory documents, auditing work plans, marketing and training services for financial institutions. Since 1989, we have built a reputation based on technical quality and dedication to client service. Visit out Website at www.thouston.com.
First published on BankersOnline.com 6/12/06
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