How long are (reconverting) banks retaining the original paper checks after they truncate? JUst curious. Will it depend on the size of the check or some other factors or will you just keep the same schedule that you currently have for your deposit customers who have agreed to check truncation?

Matt, as you know there is no requirement in Check 21 nor any guidelines regarding retention. Just as creating a Substitue Check is based on a business value, the corresponding retention will be based on risk associated with the business value that made the decision to create the substitute check in the first place. We (Fiserv) have not finalized our plans but there will be consideration to dollar value as well as type of susbtitute check created. Fiserv is also in various phases of conversation with a number of large banks to be a nationwide print provider and this topic is a banks decision and I don't believe any have finalized their plans in this area.

Only as an example of the thought process Bill lays out, Endpoint Exchange reportedly requires its members to keep the originals 61 days.

We would never go for that. We're one of the largest banks in the country and we process a boat-load of checks each day. We're considering keeping the originals for 10 or 20 days -- for large items -- but if we can get a good copy of the original item, it seems unreasonable to retain the original for 61 days.

I'm curious if other large banks plan on retaining originals for extended periods of time.

Matt, if your bank is an ECCHO member there is probably someone who sits on the ECCHO Operations Committee and has access to counterparts at the other banks. That might be a better source rather than hoping someone is watching this message board and will give you an answer. I sit on that group and have not had specific discussion but I sense the banks are still trying to get their arms around retention, both for Substitute check printing as well as image exchange. To Ken's mention of Endpoint Exchange's current 61 day retention, I understand there are plans to reduce the number of days. I am not sure if that will change to a bank decision versus the exchange network decision. It is my understadning that the SVPCo banks, who will be goverened by ECCHO rules, will make their own decision, even though ECCHO rules state a recommended minimum of 3 business days follwoing day of deposit.

For comparison only, the NACHA rules for ARC entries (lockbox checks converted to EFT's) require the Originator to retain "a reproducible, legible, image, microfilim, or copy of the front and back of the receiver's source document for two years..."

However, they also require that the original document be destroyed within 14 days. As explained: This requirement is to protect against the risk that, by error, the source document might subsequently be entered into the check processing system for payment as a check.