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#1251463 - 09/16/09 07:43 PM RDC & NBFI's??
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Are any of you offering RDC to your MSBs, NBFIs and C-Stores? My bank is looking at doing that and I wanted to see how others are handling it as it relates to BSA.

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#1251856 - 09/17/09 01:19 PM Re: RDC ?? nemsi
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If someone suggests you do not need to do this much analysis, share this with them. The highlight reel:


Effective immediately, the Bank shall cease and desist from processing Remote Deposit Capture (“RDC”) transactions for money service businesses until such time as the Bank has developed and the Board has adopted and implemented, risk management systems, written policies and procedures, and a Bank Secrecy Act/Anti-Money Laundering program, in accordance with 12 C.F.R. § 21.21, that will result in due diligence on the Bank’s customers, their lines of business, the parties to whom their customers are providing services through the Bank and those customers’ lines of business, and the effective monitoring, detection, and reporting of suspicious activities in the processing of RDC transactions
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1251904 - 09/17/09 01:58 PM Re: RDC ?? Elwood P. Dowd
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Thanks Ken.

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#1251967 - 09/17/09 02:33 PM Re: RDC ?? nemsi
Retread Offline
Power Poster
Retread
Joined: Oct 2003
Posts: 2,548
Southeast
Here's the FFIEC Guidance if you want it.

http://www.ffiec.gov/pdf/pr011409_rdc_guidance.pdf
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Politicians are like diapers. They need to be changed often and for the same reason.

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