We have no idea how the Fed will finalize its Reg CC proposals, but the second one had an interesting twist that proposed that a bank accepting a RDC or mRDC item for deposit would indemnify a bank that accepted the same item for physical (paper) deposit if the paper-item-deposit bank suffers a loss because the deposited item is returned as a duplicate presentment and the bank that accepted the RDC or mRDC version is does not receive a return of the item.
This still allows the last bank to present the item to absorb the charge-back, but recover from the image-accepting bank. The thinking behind this proposal is that banks that allow RDC or mRDC items to be deposited without taking the original check "off the streets" facilitate the potential for multiple deposits of the same item, thus creating risk for banks that accept the same item later.
I like the concept, although I have no idea how well or badly it would work in practice. And, of course, we still don't know if the change will ever become final.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8