If a bank receives a check for deposit through RDC, and the check is not signed by the maker, can the bank put extended hold on deposit for 7 days?

Has the Fed opined yet whether RDC-deposited items are even subject to Reg CC (at one time, the unpublished word was NO because the deposits aren't made at a branch of a bank).

If the RDC check is subject to Reg CC, you certainly could place a Reasonable Doubt hold based on the fact the check isn't signed.

John, if they are not subject to Reg CC, does that mean a hold can be placed for whatever length of time we deem reasonable for the item to be returned (or the drawee bank contacted?)

Regardless of how long a hold you could put on the deposit, the fact is the item is not properly payable by the drawee bank because, without a signature, the customer has not ordered its bank to make payment. If you accept the deposit, you have a defect apparent on the face of the item. If it's a large dollar item, I would not credit the customer's account with this deposit and instead suggest they take the original and go get it signed.

Are you saying that at the current time, RDC checks deposited are not subject to Reg CC requirements? Wouldn't they be considered the same as 'substitute checks'?

I may have raised a red herring. At one time there was discussion between, as I recall, the OCC and the FRB over whether a deposit of checks made via RDC would be subject to Regulation CC's hold limits under §§229.10, 229.12 and 229.13. At the time, there was an unofficial statement made that because the checks weren't considered deposited at a bank branch, the funds availability rules wouldn't apply. I have not seen a mention of that discussion again, and it may have been buried.

A check captured by RDC is most definitely NOT a substitute check, because a substitute check is a paper item. The RDC captured image may at some time in the check processing cycle be reconverted to a substitute check, if all the legal requirements of a substitute check are met, but it's not a substitute check unless it's reconverted back into that specific paper format.

stupid question, but does Reg CC even apply to business accounts?

Yes, it does.