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.

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

Thanks Ken.

Here's the FFIEC Guidance if you want it.

http://www.ffiec.gov/pdf/pr011409_rdc_guidance.pdf