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#1938325 - 07/08/14 12:46 PM Remote Deposit Capture - Limits Disclosure
C-Lo Offline
Junior Member
Joined: Nov 2013
Posts: 47
Ohio
We're in the process of onboarding a new Commercial RDC vendor and a question came up in our meeting the other day regarding disclosure of RDC limits. Are others disclosing limits to their business customers? If we impose limits and don't disclose, are we in danger of being deceptive? Thanks in advance for your help!
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Deposits and Payments
#1938328 - 07/08/14 12:50 PM Re: Remote Deposit Capture - Limits Disclosure C-Lo
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If you do not tell the customer, how will the customer know how much they can deposit remotely?
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#1938357 - 07/08/14 01:50 PM Re: Remote Deposit Capture - Limits Disclosure Kathleen O. Blanchard
C-Lo Offline
Junior Member
Joined: Nov 2013
Posts: 47
Ohio
Originally Posted By: Kathleen B
If you do not tell the customer, how will the customer know how much they can deposit remotely?


Compliance hole-heartedly agrees, but the LOB is making the argument that they'll have to have uncomfortable conversations about how the limits are determined with the customer. I think they can figure out a way to do this.
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#1938376 - 07/08/14 02:18 PM Re: Remote Deposit Capture - Limits Disclosure C-Lo
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
They should be used to those conversations!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1938440 - 07/08/14 03:41 PM Re: Remote Deposit Capture - Limits Disclosure Kathleen O. Blanchard
C-Lo Offline
Junior Member
Joined: Nov 2013
Posts: 47
Ohio
Haha! Agreed. Thanks for your feedback!
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#1939011 - 07/09/14 05:57 PM Re: Remote Deposit Capture - Limits Disclosure C-Lo
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Customer to banker: "You can have that uncomfortable discussion with me now when I can use it to avoid problems, or you can have it with me later after those limits have already caused me problems. Which do you think will be the more uncomfortable discussion?"

You set the customer's expectations up front.
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BankersOnline.com
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#1939172 - 07/09/14 10:00 PM Re: Remote Deposit Capture - Limits Disclosure C-Lo
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Limits are based on customers activity at previous bank. Simple conversation
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