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#162613 - 02/23/04 04:54 PM Imaging Checks
Anonymous
Unregistered

As a third party processor we accept mortgage payments. Can someone provide the regulation that requires organizations to scan and image checks prior sending them to a depository bank for deposit?

I know this is a requirement but I can't find the actual regulation.

Please help.
Thank you

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Operations Compliance
#162614 - 02/24/04 12:52 AM Re: Imaging Checks
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
I am not so sure it is in a regulation but I cannot imagine a bank not filming checks.
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My opinions are not legal advice and are worth what you paid for them.

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#162615 - 02/24/04 03:13 PM Re: Imaging Checks
Paragon Offline
Diamond Poster
Paragon
Joined: Dec 2003
Posts: 2,164
I doubt that there is a regulation covering this, but there is probably a requirement in the insurance coverage area, e.g. re-construction of the "transit" that is lost or stolen. Look on the other side - what would you do if the checks were lost or stolen in transit? Yes, you can go back to the payer, but going to film, etc. is a much more efficient process.

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#162616 - 02/24/04 10:13 PM Re: Imaging Checks
Anonymous
Unregistered

You should look at the FFIEC IT guidelines for contingency planning. This is what the examiners use when they cite banks for this weakness.

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#162617 - 02/25/04 11:02 AM Re: Imaging Checks
Anonymous
Unregistered

Thanks for the responses and I did check the FFIEC handbook and was very surprised when I didn't see a requirement. I'm a little surprised that one of my co-workers is asking me this, even if not a requirement it is a best practice.

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