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#1445380 - 09/20/10 05:07 PM Check kiting and RDC
Retread Offline
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Retread
Joined: Oct 2003
Posts: 2,548
Southeast
Thought some of you might find this interesting.

http://www.justice.gov/usao/nj/press/press/files/pdffiles/Kelliher,%20Denis%20Sentencing%20PR.pdf
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#1445652 - 09/21/10 12:42 AM Re: Check kiting and RDC Retread
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
Just goes to prove that proper pre-screening of RDC customers and the real-time monitoring of actual deposits are important internal control fuctions.
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#1445918 - 09/21/10 04:58 PM Re: Check kiting and RDC rlcarey
complybsa Offline
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complybsa
Joined: Sep 2008
Posts: 80
New Jersey
We only just recently started RDC and currently look at every check - was wondering how others are handling this - with a large volume of deposits??

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#1445940 - 09/21/10 05:15 PM Re: Check kiting and RDC complybsa
Elwood P. Dowd Offline
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Next to Harvey
This whole RDC thing, the regulatory fixation on "the lost information," fascinates me. For those who respond to complybsa to indicate how often you are reviewing the deposits now, please add how often you reviewed them when they were still on paper.
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#1445962 - 09/21/10 05:27 PM Re: Check kiting and RDC Elwood P. Dowd
Lilly C Offline
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Lilly C
Joined: Dec 2004
Posts: 209
Sunny Florida
I review them just as often as the customer that do not use RDC. I think the whole key is knowing your customer before you sell them the RDC. I do a whole BSA profile on them and then monitor them the first month or so then after that they are just like any other customer. Makes no difference in terms of deposit amounts, etc.

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#1446262 - 09/21/10 10:40 PM Re: Check kiting and RDC Lilly C
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
"This whole RDC thing, the regulatory fixation on "the lost information," fascinates me"

Well, IMHO there are a couple of things that may contribute to an environment of lesser control than with over the counter deposits. First, a teller has no opportunity to flip though the deposit for a cursury review as most banks require and also, branch personnel get to know customers that show up "every day" and the content of their deposits, especially a new customer would more likely to be reviewed. This still remains a valuable resource for the indentification of potential kites. Second, depending on the sophistication of the bank's RDC software and processing, many RDC deposits by-pass the typical kiting analysis software.

So the focus on "lost information" may be legitimate depending on the individual bank's processes. I am not suggesting that "real-time" monitoring consists of physically looking at each deposit.
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#1447185 - 09/23/10 01:43 PM Re: Check kiting and RDC rlcarey
Elwood P. Dowd Offline
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My issue is with the apparent regulatory presumption that banks reviewed the items before, but once they go to RDC they will automatically stop unless big brother steps in to keep them on the straight & narrow. I don't think the presumption is valid; I'm not certain all banks were doing it and in those that did the value of a teller review would fluctuate from one window to the next.

I do think a teller capable of breathing would have noticed the fact situation Retread linked to start this thread. My assumption was that bank was not reviewing the items being remotely deposited, but I don't know that they were reviewing them before they gave the customer the gizmo.

I've had some bankers point out that RDC improved their ability to review deposits because it allowed them to centralize it it and have someone with more varied experience and imagination than a teller look at them.

Now that thing about bypassing other monitoring systems...that's scary.
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