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#1495378 - 01/14/11 03:34 PM Remote Deposit Capture
AFaquir Offline
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I have seen various policies where banks are instituting transaction limits for RDC for their customers.

The FFIEC guidance makes no mention of this as a requirement nor does it suggest this should be considered...

So I am wondering why banks are doing it? Is there something in my risk assessment I am missing?
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#1495716 - 01/14/11 07:03 PM Re: Remote Deposit Capture AFaquir
rlcarey Online
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Try this document:

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

Also the FFIEC IT Examination Manual.
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#1496331 - 01/18/11 04:32 PM Re: Remote Deposit Capture rlcarey
AFaquir Offline
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I've read and now re-read the document... one small mention of "transaction Thresholds" No real explanation as to why other than in the reporting and further mitigation section.

Still don't quite understand the importance of "limiting" a customers ability to make deposits, when you wouldn't do the same in person... but I don't write the rules, I just follow them.
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#1496356 - 01/18/11 05:03 PM Re: Remote Deposit Capture AFaquir
isaidno Offline
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My bank has a default limit set at $200,000. Deposits are subject to ordinary Reg. CC rules so we have some ability to protect ourselves and our technology is able to detect invalid R/T numbers. The limit really hasn't been an issue for our clients.

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#1496369 - 01/18/11 05:20 PM Re: Remote Deposit Capture isaidno
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If you don't have thresholds, monitoring and other internal controls, what would prevent a customer from running several million dollars of fake or duplicate items into their account in one or two days and then disappear? You can't tell me that a $1 million deposit at the teller window goes unnoticed. It is just plain old sound risk management controls.
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#1496494 - 01/18/11 07:01 PM Re: Remote Deposit Capture rlcarey
AFaquir Offline
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RL, of course a million dollar deposit at the teller window gets noticed, we're a small group, we'd probably all probably pose for pictures with a check that large. However, I'll bet at most banks a $10K one goes through no questions asked in person from most business customers, regardless of transaction history.

I think on RDC a transaction limit is a false sense of security and relatively inconvenient for customers... when "evil-doers" could just as easily submit deposits up to that limit without exceeding and go unnoticed... Bank's should be monitoring actively anyways... but now I will be putting in a limit per the guidance and "supposedly" best practices of the industry.

ISAIDNO: I think I could set a $200,000 annual limit for customers and be just fine... is that your daily limit?
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#1496527 - 01/18/11 07:39 PM Re: Remote Deposit Capture AFaquir
rlcarey Online
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It is just one of the many controls for RDC and does not represent a panacea of safety.
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#1496587 - 01/18/11 08:23 PM Re: Remote Deposit Capture rlcarey
AFaquir Offline
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RL: Agreed... and that's sound risk management!
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#1496741 - 01/18/11 11:19 PM Re: Remote Deposit Capture AFaquir
isaidno Offline
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It is a daily limit set based on the risk the bank is willing to take. Of course, we will lower the limit if the individual credit risk assessment of the client warrants it. Each RDC client has a Commercial Loan Officer who has a relationship with the client and is involved in the determination.

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